T. M. v. University of Md. Medical System Corporation

Docket Number: 25-197
Citation: 608/2
Term: October Term 2025
Argued: April 20, 2026
Decided: June 18, 2026
Lower Court: United States Court of Appeals for the Fourth Circuit
Author: Associate Justice Sonia Sotomayor
Concurring: Sonia Sotomayor, Clarence Thomas, Samuel A. Alito, Jr., Brett M. Kavanaugh, Ketanji Brown Jackson
Dissenting: Amy Coney Barrett, John G. Roberts, Jr., Elena Kagan, Neil M. Gorsuch

AI-Generated Summary

Case Information:

Case Name: T. M. v. University of Maryland Medical System Corporation et al.
Docket Number: 25–197
Dates: Argued April 20, 2026—Decided June 18, 2026
Lower Court: United States Court of Appeals for the Fourth Circuit

Facts of the Case:

Petitioner T. M. alleges a medical condition causing psychosis upon ingesting gluten. In March 2023, after accidental ingestion, she was taken to an emergency room, involuntarily committed for three months following an administrative hearing, and subjected to an order authorizing forced antipsychotic injections.
Multiple state and federal lawsuits followed seeking release and to block the injections. The parties negotiated a settlement; a state judge entered it as a consent order on June 12, 2023, providing for immediate release subject to conditions including medication compliance and dismissal of pending actions.
Ten days later, T. M. and her parents filed this federal action in the District of Maryland seeking declarations that the consent order violated due-process rights and was obtained under duress, plus an injunction against enforcement. T. M. simultaneously appealed the consent order in state court and obtained a stay of that appeal.

Legal Issues Presented:

The primary question is whether the Rooker-Feldman doctrine bars federal district-court jurisdiction only over final judgments rendered by the highest court of a State in which a decision could be had (under 28 U.S.C. §1257(a)), or whether it also applies when the state-court judgment remains subject to further state appellate review.
The case involves interpretation of federal jurisdictional statutes (§§1257 and 1331) and the scope of the Rooker-Feldman doctrine as articulated in prior precedents.
Petitioner argued for a narrow reading limiting the doctrine to §1257 final judgments; respondents (and the lower courts) contended that the doctrine applies more broadly whenever a federal plaintiff seeks review and rejection of a state-court judgment.

The Court's Decision (Main Opinion):

Author & Type: Justice Sotomayor delivered the opinion of the Court (Majority), joined by Justices Thomas, Alito, Kavanaugh, and Jackson.
Holding: The Rooker-Feldman doctrine bars federal district-court jurisdiction over cases brought by state-court losers complaining of injuries caused by state-court judgments rendered before the district-court proceedings commenced and seeking district-court review and rejection of those judgments, regardless of whether the state-court judgment remains subject to further review in state appellate proceedings.
Legal Reasoning: The doctrine rests on the distinction between original and appellate jurisdiction. Federal district courts possess only original jurisdiction under §1331; only this Court has appellate jurisdiction under §1257(a) to review state-court judgments. Precedents (Rooker, Feldman, Exxon) adopt a functional view: seeking to reverse or modify a state-court judgment is an exercise of appellate jurisdiction that district courts lack. The consent order was rendered before the federal suit and T. M. plainly seeks its review and rejection.
Disposition: The judgment of the Fourth Circuit affirming dismissal for lack of subject-matter jurisdiction is affirmed.

Concurring Opinion(s):

Justice Thomas filed a concurring opinion. He agrees that Rooker is correct as an original matter, emphasizing that the power to revise another court’s judgment is appellate in nature and that Congress has never granted district courts general revising power over state-court judgments.

Dissenting Opinion(s):

Justice Barrett filed a dissenting opinion, joined by Chief Justice Roberts and Justices Kagan and Gorsuch. The dissent argues that Exxon confined Rooker-Feldman to cases in which state proceedings had ended (i.e., final judgments from the highest state court under §1257), that the majority improperly revives a discarded §1331 rationale, and that federalism, preclusion, and abstention doctrines adequately address the concerns without expanding the doctrine’s narrow scope.

Potential Significance:

The opinion reaffirms that Rooker-Feldman occupies only the narrow ground identified in Exxon and neither expands nor contracts the doctrine. It clarifies that the doctrine applies to any state-court judgment (final or not) when the federal plaintiff seeks review and rejection of that judgment, thereby resolving a circuit split while leaving the doctrine’s application to other contexts untouched.

This summary was generated by AI and may contain inaccuracies. Refer to the official source document for the authoritative text.

Key terms: State Court Judgments, Federal Court Review, Consent Orders