Supreme Court Decision Syllabus (SCOTUS Podcast)

T. M. v. University of Md. Medical System Corporation (RookerFeldman Doctrine)

Attorney RJ Dieken, Loki Esq Law, Montana Season 2025 Episode 49

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Hello, this is R.J. Deakin, reading the Supreme Court of the United States opinion syllabus in TM vs. University of Maryland Medical System Corporation, sortiary to the United States Court of Appeals for the Fourth Circuit. Argued April 20th, 2026, and decided June 18th, 2026. The Rooker-Feldman Doctrine bars federal district courts from exercising jurisdiction over cases brought by state court losers seeking review and rejection of state court judgments rendered before district court proceedings commenced. See ExxonMobil v. Saudi Bank Industries Corporation. This case asks whether the doctrine applies only to final judgments rendered by the highest court of a state in which a decision could be had, or whether it also bars suit when the state court judgment at issue remains subject to further review in state appellate proceedings. Petitioner TM alleges that she has a medical condition that causes changes in her mental status, including psychosis, when she ingests gluten. In March 2023, TM accidentally ingested gluten and was taken to the emergency room at Baltimore Washington Medical Center, where after an administrative hearing and over her and her father's objections, she was involuntarily committed for about three months. During her stay, TM's treating psychiatrist and the medical center obtained an order authorizing the facility to forcibly inject TM with antipsychotic medication. These events prompted a flurry of litigation, with TM and her parents filing several state and federal lawsuits seeking TM's release and to avoid the forced injection. TM and respondents negotiated a settlement agreement to facilitate TM's discharge, and the state judge presiding over TM's state habeas petition entered the agreement as a consent order on June 12, 2023. The consent order provided for TM's immediate release, subject to several conditions, including that TM obtain a new treating psychiatrist, continue taking her prescribed medications, and dismiss with prejudice all pending actions against respondents. Ten days after the state court entered the consent order, TM and her parents obtained new counsel and sued respondents in federal district court for the District of Maryland, seeking a declaration that the consent order violated TM's federal and state due process rights, and a declaration that the order was obtained under duress and an injunction preventing its enforcement. Meanwhile, TM appealed the consent order to the appellate court of Maryland and raised similar arguments. TM later successfully moved to stay the state court appeal to prevent inconsistent rulings. The District Court dismissed the complaint, suasponte, for lack of subject matter jurisdiction under the Rooker Feldman Doctrine, and the Fourth Circuit affirmed, rejecting TM's argument that the Rooker Feldman applies only to judgments that are final judgments from the highest court of a state in which the decision could be had. Supreme Court held decision is affirmed, Justice Sotomayora delivered the opinion. Federal district courts generally lack any power to review, uh to review directly cases from state courts. That's Atlantic Coastline Railroad Corporation versus Locomotive Engineers. The Supreme Court is the only federal court with appellate jurisdiction to review state court judgments, and that jurisdiction extends only to final judgments or decrees rendered by the highest court of a state in which a decision could be had. In Rooker v. Fidelity Trust, the court held that a federal district court lacked jurisdiction to declare a state court judgment null and void, because doing so would be an exercise of appellate jurisdiction, which only the Supreme Court possesses, and the jurisdiction possessed by the district courts is strictly original. In District of Columbia Court of Appeals versus Feldman, the court held that a federal district court lacked jurisdiction to review a final judicial determination of the DC High Court, because such a review can be obtained only in the Supreme Court under Section 1257. Rooker and Feldman rest on two closely related bases of reasoning. First, when plaintiffs essentially invite federal courts of first instance to review and reverse unfavorable state court judgments, they are seeking an exercise of appellate jurisdiction. That's Exxon. Second, such appellate jurisdiction to reverse or modify a state court judgment is lodged by Section 28 USC, Section 1257, exclusively in the Supreme Court. That's uh 544 U.S. 283. This court has since refused to expand the Rucker Feldman doctrine, but has also reaffirmed its rule in the narrow ground it occupies. That's uh Exxon again. DM's case falls within the narrow ground occupied by Rucker Feldman, that's uh citing Exxon, because she is complaining of injuries caused by and seeking relief from the state court judgment itself, arguing that the consent order violates her federal and state due process rights and was entered into uh under duress. The consent order was rendered ten days before TM commenced this federal lawsuit, and she plainly seeks review and rejection of the consent order by asking the district court to declare it unconstitutional, unenforceable, and void ab in idiot, and enjoin its enforcement. Uh the court rejects TM's argument that Rucker Feldman should apply only to final judgments rendered by the highest court of a state in which a decision could be had, i.e., the kinds of judgment that strictly fall within this court's jurisdiction under 28 USC section 1257. TM's theory cannot be squared with the court's precedence. TM reads the court's prior Rucker Feldman cases not to evince any concern about district courts exercising what amounts to appellate jurisdiction over state court judgments, but instead as relying on a strict negative inference from section twelve fifty seven, when this court has jurisdiction over a state court judgment, district courts must not. But this court's precedence plainly adopted a more functional view of what constitutes original and appellate jurisdiction under section 1331. In Rooker, nothing in the court's reasoning suggested the outcome would have been different had the judgment still been on appeal. The court held that seeking to reverse or modify the state court judgment would be an exercise of appellate jurisdiction, which the district court lacks because it has strictly original jurisdiction. Later cases confirmed that Rooker Feldman bars suits in federal district court that seek what, in substance, would be appellate review of a state judgment, regardless of whether the judgment formally falls within this court's Section 1257 jurisdiction. That's Johnson versus D. Gunt D. Grandy. In fact, Feldman explicitly rejected the notion that district courts have jurisdiction to review state court judgments so long as the judgments are not yet within this court's 1257 jurisdiction. That's 460 U.S. at 483, uh note 16, explaining that irrespective of the court's jurisdiction to review a final state court judgment, lower federal courts possess no power whatever to sit in direct review of state court decisions. If departure from this court's precedence alone were not enough to confirm the dismissal of TM's suit under Rucker Feldman, adopting TM's rule would also create anomalous outcomes and undermine federalism principles, allowing federal district courts to review state court judgments while they are on appeal in the state court system would undermine the cooperation and comedy on which the national or the nation's federal system is built. That's Rugas AG versus Marathon Oil. TM's rule would also produce arbitrarily different results depending on when a federal suit seeking review of state court judgments is filed, encouraging parties to file earlier in federal court while the state appellate proceedings are pending, and to duplicate their efforts, even though the state process may resolve the dispute in their favor. TM's contention that abstention and preclusion doctrines can do nearly all of the work that Rooker Feldman does is unavailing. It is unclear if such doctrines even apply in cases where a plaintiff complains of injuries that stem directly from a state court judgment rather than attempting to relitigate the same claims. Federalism principles are thus best served by continuing to apply Rokerfeldman to federal plaintiffs seeking review of state court judgments, regardless of whether those judgments are final trial court judgments or those of a state's highest court. TM contends that the court should adopt her position because it will generally cabin Roker Feldman, a doctrine she claims has caused confusion and is overused as a docket clearing mechanism in the lower courts. TM's proposed rule would fail to address the source of confusion in current Roker Feldman doctrine, determining when a plaintiff is seeking federal review and rejection of a state court judgment, and would add a new source of confusion by requiring courts to determine whether a state court judgment is a reviewable final judgment under Section 1257A. In any event, the animating force between behind TM's arguments is the belief that Rooker and Feldman were wrongly decided. But this issue is not fairly included in the question presented. The court today neither expands nor constrains Rooker Feldman, but leaves the doctrine as it found it. The decision below is affirmed. Justice Sotomero delivered the opinion of the court in which Justices Thomas, Alito, Kavanaugh, and Jackson joined. Justice Thomas filed a concurring opinion. Justice Barrett filed a dissenting opinion in which Justice Roberts and Kagan and Gorsuch joined. Thanks for listening. I am painfully aware of the uh the state district court not being able to r uh bind the lower state courts because I could not properly convince a non lawyer justice of the peace that um that that uh a federal court opinion was even persuasive at all.