T. M. alleged that she has a medical condition that causes changes in her mental status, including psychosis, when she ingests gluten. In March 2023, T. M. 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, T. M.’s treating psychiatrist and the medical center obtained an order authorizing the facility to forcibly inject T. M. with antipsychotic medication.
T. M. and her parents filed several state and federal lawsuits seeking T. M.’s release and to avoid the forced injections. T. M. and the defendants negotiated a settlement agreement to facilitate T. M.’s discharge, and the state judge presiding over T. M.’s state habeas petition entered the agreement as a consent order on June 12, 2023.
The consent order provided for T. M.’s immediate release subject to several conditions, including that T. M. obtain a new treating psychiatrist, continue taking her prescribed medications, and dismiss with prejudice all pending actions against the defendants. Ten days after the state court entered the consent order, T. M. and her parents obtained new counsel and sued the defendants in Federal District Court for the District of Maryland, seeking a declaration that the consent order violated T. M.’s federal and state due-process rights, a declaration that the order was obtained under duress, and an injunction preventing its enforcement. Meanwhile, T. M. appealed the consent order to the Appellate Court of Maryland and raised similar arguments. T. M. later successfully moved to stay the state-court appeal to prevent inconsistent rulings. The District Court dismissed the complaint sua sponte for lack of subject matter jurisdiction under the Rooker-Feldman doctrine. The Fourth Circuit affirmed, rejecting T. M.’s argument that Rooker-Feldman applies only to judgments that are final judgments from the highest court of a State in which the decision could be had.
Rooker-Feldman Doctrine
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.
In Rooker v. Fidelity Trust Co., 263 U. S. 413, the United States Supreme 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 v. Feldman, 460 U. S. 462, the United States Supreme Court held that a Federal District Court lacked jurisdiction to “review” a final judicial determination of the D. C. high court because such “[r]eview . . . can be obtained only in [the Supreme] Court” under §1257.
The issue presented to the United States Supreme Court in the present case was whether the Rooker-Feldman 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.
The United States Supreme Court held in its June 18, 2026 Slip Opinion that 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. T. M.’s case falls within the narrow ground occupied by Rooker-Feldman 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 under duress. The consent order was rendered 10 days before T. M. commenced her 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 initio” and to enjoin its “enforcement.”
“[T]he the animating force behind many of T. M.’s and the dissent’s arguments appears to be the belief that Rooker and Feldman were wrongly decided and so should be cabined whenever possible, if not outright overruled. Cf. post, at 2–5 (raising doubts about Rooker-Feldman’s conceptual basis). This issue is not fairly included in the question presented and was not pressed at the certiorari stage. See this Court’s Rule 14.1(a).”
“The Court today neither expands nor constrains Rooker-Feldman. Instead, the Court leaves the doctrine as it found it: narrowly confined to “cases brought by state-court losers complaining of injuries caused by state-court judgments rendered before the district court proceedings commenced and inviting district court review and rejection of those judgments.” Exxon, 544 U. S., at 284. Because T. M.’s suit falls within these strict limits, the judgment of the Court of Appeals for the Fourth Circuit is affirmed.”
Source T. M. v. University of MD. Medical System Corporation, No. 25-197, 608 U. S. __ (2026).
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