T.M. v. University of Maryland Medical System Corp.

    Issues

    Does the Rooker-Feldman doctrine prohibit a plaintiff from challenging a state court judgment in federal court while an appeal in state court is still possible? 

    Oral argument:
    April 20, 2026
    Court below:
    United States Court of Appeals for the Fourth Circuit

    The Supreme Court will decide whether the Rooker-Feldman doctrine applies to Petitioner T.M.’s case, wherein T.M. filed a claim in a federal court challenging a state court judgment before the state court judgment’s appeal window closed. T.M. argues that the Rooker-Feldman doctrine does not apply to her case because her state court judgment was not final or issued by the state’s highest court. If Rooker-Feldman applies to her case, T.M. asks the court to overturn the doctrine. Respondents, including the University of Maryland Medical System Corporation (“UMMS”), counter that the Rooker-Feldman doctrine should bar T.M.’s case because it meets all elements required by the doctrine. UMMS posits that any arguments that ask the Court to overturn Rooker-Feldman are beyond the scope of the question the Court has before it. The outcome of this case will have significant implications for litigation incentives and the relationship between federal and state courts.

    Questions as Framed for the Court by the Parties

    Whether the Rooker-Feldman doctrine, which prevents parties who lose in state courts from challenging injuries caused by state-court judgments, can be triggered by a state-court decision that remains subject to further review in state court.

    Facts

    The petitioner, whose identity has been anonymized to the initials “T.M.,” experienced a medical episode in 2023. T.M. has a condition that can alter her mental state if she consumes gluten in her diet. T.M. was admitted to the University of Maryland Baltimore Washington Medical Center’s emergency department, which is operated by the University of Maryland Medical System Corporation (“UMMS”). T.M. and her father requested that T.M. be admitted voluntarily, but T.M. was instead involuntarily committed for treatment at the medical center. While being treated at the hospital, a psychiatrist providing care to T.M. attempted to involuntarily administer a medication by injection. A medical review board endorsed T.M.’s psychiatrist’s method of treatment, and an administrative law judge affirmed the treatment. 

    T.M. challenged both her involuntary commitment and forced injection treatment by filing lawsuits in state and federal court. Before T.M.’s state habeas case concluded, T.M. and the medical center came to an agreement for her treatment. T.M. and the medical center confirmed their agreement by proposing it to the state court, which was approved and entered as a consent order. The medical center released T.M. after the consent order was adopted.

    T.M. then filed a subsequent lawsuit in a federal court, the United States District Court for the District of Maryland (the “District Court”). T.M.’s lawsuit alleged that the consent order was unconstitutional. T.M.’s complaint argued that the consent order violates her fundamental right to refuse medical care and that she did not voluntarily agree to the consent order. The District Court dismissed T.M.’s claims, finding that it could not hear them because it lacked subject matter jurisdiction over them. Specifically, because of a legal doctrine named the Rooker-Feldman doctrine, the District Court determined that it did not have jurisdiction to hear the matter.

    While T.M.’s federal case was pending, T.M. appealed the state court’s consent order to the Appellate Court of Maryland. The Appellate Court of Maryland stayed T.M.’s state appeal proceedings while she litigated her federal court case.

    T.M. appealed the District Court’s decision to the United States Court of Appeals for the Fourth Circuit (the “Court of Appeals”). The Court of Appeals unanimously upheld the District Court’s ruling. The Court of Appeals also found that the Rooker-Feldman doctrine prevented the District Court from hearing T.M.’s claims.

    T.M. petitioned the Supreme Court of the United States (the “Supreme Court”) for review of the Court of Appeals’ decision by filing a petition for a writ of certiorari. The Supreme Court granted the petition on December 5, 2025.

    Analysis

    THE ROOKER-FELDMAN DOCTRINE’S APPLICABILITY

    T.M. argues that the lower courts erred by concluding that the Rooker-Feldman doctrine applied to her case. T.M. asserts that the Rooker-Feldman doctrine is a federal court rule that prevents a federal court from reviewing a state court judgment. However, T.M. contends that the Rooker-Feldman doctrine only activates when a petitioner files a claim in federal court challenging the highest available state court’s final decision. T.M. highlights that the Supreme Court has only applied the Rooker-Feldman doctrine in two cases to prevent a federal district court from having jurisdiction to hear a case: Rooker v. Fidelity Trust Co. and District of Columbia Court of Appeals v. Feldman. Most recently, T.M. flags that the Court explicitly limited the doctrine’s applicability in Exxon Mobil Corp. v. Saudi Basic Industries Corp. when it refused to apply the doctrine to a federal action, despite an identical state action simultaneously pending. In Exxon Mobil, according to T.M., the Court highlighted how lower federal courts in the years post-Feldman expanded the Rooker-Feldman doctrine far beyond its narrow applicability.

    T.M. asserts that the Rooker-Feldman doctrine has never been applied to a case filed in federal court while the federal plaintiff’s state court claims were still pending. T.M. claims that the Rooker-Feldman doctrine developed from a predecessor of 28 U.S.C. § 1257, the statute that allows petitioners to file writs of certiorari to the Supreme Court to appeal final state court decisions. T.M. asserts that because the statute permits only the Supreme Court to hear cases where a state’s highest court has issued its final judgment, the Rooker-Feldman doctrine indicates the negative inference that federal district courts cannot hear only those cases. As such, T.M. contends that the Rooker-Feldman doctrine applies to a narrow class of cases where a plaintiff files a suit in a federal court after the highest applicable state court has issued its final judgment. T.M. asserts that a judgment with an appeal still pending cannot apply because it is not final. T.M. thus argues that there is an additional requirement for Rooker-Feldman: it only applies in cases where the state proceedings have ended because the highest applicable court has entered a final judgment. T.M. notes that in both Rooker and Feldman, the highest state court and the highest available court had issued a final judgment against the federal plaintiff.

    Additionally, T.M. notes that in her case, the state court’s judgment was not final and could be appealed at the time T.M. filed her federal lawsuit. T.M. filed her petition in federal court after a state court entered her consent order, but T.M. was still in the process of appealing her state court’s order to the Appellate Court of Maryland. Thus, because T.M.’s case was not a final judgment issued by the highest applicable state court, she argues that she could not petition for a writ of certiorari via 28 U.S.C. § 1257 to appeal her judgment and that the Rooker-Feldman doctrine should not apply to her case.

    The Respondents, including UMMS (collectively, “UMMS”), argue that the Rooker-Feldman doctrine applies regardless of whether a state court’s judgment is final or subject to further review. UMMS posits that the Rooker-Feldman doctrine applies when four elements are met. First, UMMS argues the plaintiff in the federal lawsuit must be the losing party in state court. Second, UMMS states that the plaintiff must allege that the state court’s judgment causes them some harm. Third, UMMS contends that the state court’s judgment must be entered before the plaintiff files in federal court. Fourth, UMMS asserts that the plaintiff must ask the federal district court to look at the state court’s judgment and declare it invalid. UMMS argues that T.M.’s case fulfills each element. UMMS first notes that T.M. is the plaintiff in the federal district court and that she first lost in state court. UMMS asserts that T.M. is arguing that the consent order, entered as a judgment, has harmed her. UMMS contends that it does not matter that T.M.’s judgment was entered after a mutual consent order. UMMS highlights that T.M. filed in federal court after the Maryland state court entered its judgment, and that T.M. is asking the federal court to examine and void it, fulfilling the third and fourth requirements.

    UMMS notes that even though Rooker-Felman is based on 28 U.S.C. § 1257, the doctrine goes further than what may be directly inferred from the statute. UMMS argues that a federal court improperly exercises appellate jurisdiction when it reviews a state court’s decision on the merits because of an alleged constitutional violation. UMMS notes that only the Supreme Court, through 28 U.S.C. § 1257, is empowered to exercise appellate jurisdiction on the merits over a state court’s final judgment. UMMS believes that T.M.’s argument that Rooker-Feldman is based solely on a negative inference from 28 U.S.C. § 1257 is misplaced, because the doctrine extends beyond the limits of the negative inference. UMMS agrees that 28 U.S.C. § 1257 applies to judgments that are final and have reached the state’s highest court. But UMMS contends that Rooker-Feldman goes further than the statute by also applying to judgments that have not reached a state’s highest court, such as when the window for further appeal has expired.

    UMMS further argues that the Rooker-Feldman doctrine does not require the state court’s judgment to be final or issued by the state’s highest court. UMMS states that while the judgments in Rooker and Feldman were “final,” the word “final” as used by the Court was merely a description of the cases’ procedural history. UMMS contends that whether the judgment was made by a state’s intermediate appellate court or its highest court, Rooker-Feldman applies.

    THE ROOKER-FELDMAN DOCTRINE’S LEGITIMACY

    T.M. argues in the alternative that the Court should consider the legitimacy of the Rooker-Feldman doctrine. T.M. asserts that Rooker-Feldman cannot pass a stare decisis analysis. T.M. contends that Rooker-Feldman has not been a workable doctrine for lower courts, as lower courts are often confused in its application. Moreover, T.M. believes that neither Congress nor litigants have any interests relying on the doctrine’s application. Finally, T.M. asserts that while stare decisis commands the Court to follow prior rulings, this command holds less weight when it is applied to procedural rules that govern jurisdiction. T.M. further notes that no language in 28 U.S.C. § 1257 prevents a federal district court from having the ability to hear a case it would otherwise normally be able to hear, and that the doctrine itself is judicially created from a negative inference. Moreover, T.M. illustrates other situations where federal and state appellate jurisdictions can both be raised simultaneously.

    UMMS argues that T.M.’s argument for overturning Rooker-Feldman is improper and should be ignored by the Court. UMMS notes that there is over a century of legal precedent supporting the Rooker-Feldman doctrine. Moreover, UMMS argues that the Court granted review over whether the Rooker-Feldman doctrine applies to T.M.’s case, and any argument about the doctrine’s soundness is beyond the scope of review. UMMS notes that T.M.’s certiorari petition solely focused on a federal court circuit split about the doctrine’s application in cases like T.M.’s. UMMS further argues that T.M.’s argument is improper because neither party has fully briefed the issue of Rooker-Feldman’s legitimacy.

    Discussion

    FEDERALISM INTERESTS

    Federal courts scholars, in support of T.M., argue that expanding the Rooker-Feldman doctrine is not necessary to protect federalism interests because other doctrines already exist to address challenges posed by parallel litigation. Federal courts scholars point out that claim preclusion and issue preclusion prevent federal courts from relitigating what a state court has already decided. Similarly, federal courts scholars note that abstention doctrines require federal courts to defer to certain state proceedings. According to federal courts scholars, these doctrines are sufficient to protect federalism concerns because they preserve the finality of state court decisions and show respect to state forums. The Institute for Justice further argues that extending Rooker-Feldman to certain non-final judgments would weaken federalism by depriving litigants of a federal forum and preventing courts from hearing claims that state courts have not yet resolved.

    UMMS argues that when federal district courts review state-court judgments while state appeals are still possible or ongoing, the court undermines federalism and comity. According to the American Medical Association and Maryland State Medical Society (collectively, “AMA”), allowing for federal parties to relitigate issues undermines the foundational premise that state courts can adjudicate federal claims. UMMS suggests that the dual system of state and federal courts requires applying the Rooker-Feldman doctrine to these circumstances to prevent federal courts from frequently intervening in state cases. UMMS contends that state appellate courts should have an opportunity to review and correct the decisions of their own lower courts. According to UMMS, allowing state court litigants to immediately seek review by a federal district court of a state judgment before state appellate courts have weighed in on the issue sends a message that state courts cannot be trusted to get it right.

    LITIGATION INCENTIVES AND FINALITY

    T.M. argues that the risk of duplicative litigation in the absence of the Rooker-Feldman doctrine is overstated because preclusion and abstention doctrines already adequately police meritless additional litigation. The Institute for Justice argues that the Rooker-Feldman doctrine’s overapplication is the actual cause of additional litigation of jurisdiction, wasting both time and resources. The Institute for Justice notes that district courts have cited Rooker-Feldman at an increasing rate over the past years, even though the Supreme Court has instructed the doctrine be interpreted narrowly. That is evidence, in the Institute for Justice’s view, that the doctrine overly burdens plaintiffs who have meritorious arguments, potentially adding years to litigation. Furthermore, the Rooker-Feldman doctrine impacts pro se litigants worst of all, as unpublished circuit opinions affirm Rooker-Feldman dismissals at higher rates than published opinions, and most dismissals involve pro se litigants. Finally, according to federal court scholars, since Rooker-Feldman dismissals are not judgments on the merits, these judgments can generate additional or protracted litigation rather than promoting finality.

    The AMA argues, in support of UMMS, that the Rooker-Feldman doctrine is an important safeguard against duplicative suits filed in federal court in an attempt to reverse adverse state court decisions. The AMA asserts that the absence of the doctrine would incentivize filing frivolous state court appeals to keep litigating in federal court. In the context of medical malpractice suits, the AMA notes that the Rooker-Feldman doctrine provides an important avenue for dismissing suits after state-court dismissals. In support of its claim, the AMA cites a study showing that most malpractice claims are dismissed, concluding that, by not applying Rooker-Feldman, there would follow a significant increase in litigation costs. The cost of defending these duplicative suits, the AMA suggests, increases malpractice insurance premiums and healthcare costs generally. Moreover, if the Rooker-Feldman doctrine is narrowed, the AMA contends that this would encourage parallel litigation in state and federal courts to maximize legal fees.
     

    Conclusion

    Authors 

    Written by:    Leonardo Costa Lins Villa-Forte and Keaton J. Klaus

    Edited by:      Sara Fischer

    Additional Resources