UPDATE ON ROOKER-FELDMAN

 UPDATE ON ROOKER-FELDMAN 

On June 18, 2026, the U.S. Supreme Court ruled in T.M. v. University of Maryland Medical System Corp. that the Rooker-Feldman doctrine deprives federal district courts of jurisdiction to review or overturn state court judgments, regardless of whether the state court judgment is final or still pending further review in state appellate proceedings. In a sharply divided 5-4 ruling, the Court confirmed that "state-court losers" cannot seek an "appeal" or a do-over in lower federal courts even if they are still actively fighting the decision within the state's appellate system.

The Core Ruling
The primary legal conclusion of the decision establishes that:
The Doctrine Applies Early: The Rooker-Feldman doctrine can be triggered before a state-court judgment becomes completely finalized. [1]
No Lower Federal Appeals: Federal district courts hold strictly original jurisdiction and completely lack the appellate authority to review, vacate, or modify injuries caused by a state-court order. [1, 2]
Exclusive SCOTUS Jurisdiction: Only the U.S. Supreme Court has the federal statutory authority to hear direct appeals resulting from state-court judicial decisions.

Case Background
The dispute originated from a Maryland woman, identified as T.M., who was involuntarily admitted to a psychiatric facility following a medical emergency. To secure her release, she agreed to a settlement agreement that was formally entered by a state judge as a consent order. [1, 2]
T.M. subsequently filed a federal civil rights lawsuit arguing the consent order violated her constitutional rights, asking a federal district court to declare the state-court order void. Because she was simultaneously appealing the consent order within the Maryland state court system, she argued Rooker-Feldman did not apply to "non-final" state decisions. [1, 2, 3] The Vote and Opinions
The case produced an unusual cross-ideological voting lineup among the justices: [1]


The Majority (5-4): Written by Justice Sonia Sotomayor, and joined by Justices Samuel Alito, Ketanji Brown Jackson, Brett Kavanaugh, and Clarence Thomas. Sotomayor wrote that a straightforward application of the doctrine's core logic means federal district courts cannot act as appellate bodies for state cases, even if a state case is actively pending. However, the majority stressed that the doctrine remains "narrow" and only bars cases where the state-court judgment itself caused the injury. [1, 2, 3, 4]


The Dissent: Written by Justice Amy Coney Barrett, and joined by Chief Justice John Roberts and Justices Neil Gorsuch and Elena Kagan. The dissenters argued that the majority extended the doctrine too far, asserting that Rooker-Feldman should strictly match federal statute 28 U.S.C. § 1257, which only limits federal review of final judgments coming from a state’s highest court. [1, 2, 3, 4, 5]

file:///home/justice/Downloads/The_Rooker_Feldman_Doctrine_The_Case_for_Putting_it_to_Work_Not.pdf

A constitutional claim is not enough. If the injury you are complaining about was caused by the state-court judgment itself, and your requested relief requires a federal district court to invalidate that judgment, Rooker-Feldman likely bars the suit. If the constitutional claim is independent of overturning the judgment, then Rooker-Feldman may not apply.