Posts Tagged ‘rooker-feldman’
Rooker-Feldman Applies Even Where State Court Decisions Are Not Final: T.M. v. University of Maryland Medical System
The Rooker-Feldman Question Presented in University of Maryland Medical System
In its 2025 Term, the Supreme Court granted certiorari in a Fourth Circuit case, T.M. v. University of Maryland Medical System, 139 F.4th 344, 353-354 (4th Cir. 2025), cert granted, 147 S. Ct.— (12-5-25)(No. 25-197), aff’d, 147 S. Ct. – (2026), to deal with the following Question Presented: “Whether the Rooker-Feldman doctrine can be triggered by a state-court decision that remains subject to further review in state court.” The Court, in an opinion for the Court by Justice Sotomayor, answered in the affirmative, with Justice Thomas concurring, and Justice Barrett, joined by Chief Justice Roberts and Justices Kagan and Gorsuch, dissenting.
The Fourth Circuit’s Decision
In this case, a patient and her parents sought to invalidate a state court’s consent order basing her release from involuntary commitment on compliance with certain conditions. The Fourth Circuit ruled that the district court correctly dismissed this § 1983 complaint under Rooker-Feldman, pointing out that the case “bears an uncanny resemblance to Rooker” which similarly sought to undo a state court judgment. It did not matter that this case involved a consent order which was itself challenged as unconstitutional; the plaintiff was still a state court loser. And even though plaintiff won in one state court, that state court case did not involve the court order that plaintiff now argued was unconstitutional. Finally, the Fourth Circuit rejected the plaintiff’s argument that Rooker-Feldman should not apply here because there was no final state court judgment. The court explained: “[W]e agree with the Sixth and Eighth Circuits that Rooker-Feldman is not limited to situations when a federal court plaintiff no longer has any recourse within the state system.” There was no “stealth fifth requirement for invoking the Rooker-Feldman doctrine.”
The Supreme Court’s Decision
Affirming, the Supreme Court explained that this case involved the “straightforward application of the logic and reasoning underlying Rooker-Feldman.” The plaintiff here complained of injuries caused by the state court judgment itself, by arguing that the consent order violated her federal and state due process rights and was entered into under duress ten days before the federal lawsuit was filed. This was the “paradigm” Rooker-Feldman situation.
The Court went on to reject the plaintiff’s argument that a new requirement should be added to Rooker-Feldman, namely, that it should apply only to final judgments entered by the highest court of the relevant state. It concluded that this proposed rule was “inconsistent with the Court’s precedents, risks producing anomalous results, and undermines federalism interests.” Instead, the Court emphasized that Rooker-Feldman was, and should continue to be, grounded on the functional distinction between original federal court jurisdiction under 28 U.S.C. § 1331 and the Supreme Court’s appellate jurisdiction over state court judgments under 28 U.S.C. § 1257. Contrary to the plaintiff’s argument and the dissenters’ position, Rooker-Feldman cases were not akin to collateral attacks brought under a federal district court’s original jurisdiction pursuant to § 1331.
The Concurring and Dissenting Opinions
Justice Thomas concurred, agreeing with the majority that Rooker-Feldman was soundly based on the “simple legal proposition that only this Court may exercise appellate jurisdiction over state-court judgments.” Justice Barrett, joined by the Chief Justice and Justices Kagan and Gorsuch, dissented, arguing that Rooker-Feldman should not apply when the underlying state court action remains pending. The seven Courts of Appeals that had previously so ruled “were right to hold the line. … Because Rooker-Feldman stands on shaky ground, we have consciously kept its footprint small. … [S]o we should make the doctrine no larger.”
The dissenters also rejected the majority’s argument that federalism principles were promoted by applying Rooker-Feldman to non-final state court judgments, particularly since the plaintiff’s suit was brought under § 1983, which had transformed traditional concepts of federalism. For this and other reasons, the majority’s ruling “muddied waters that were hardly clear to begin with.” Finally, the dissenters emphasized that, regardless of the majority’s decision in this case, the Rooker-Feldman doctrine’s scope should be narrow.
Comment
The (slim) majority got it right because the rationale of Rooker-Feldman, that federal courts do not have appellate jurisdiction over state court decisions, applies with full force to state court decisions that are not final. On the other hand, the dissenters were correct in insisting that Rooker-Feldman, at its best incredibly arcane and frequently difficult to apply consistently, should be narrow in scope.
For much more on Rooker-Feldman, including collected circuit court decisions, see §§ 1:26-1:30 in Nahmod, Civil Rights & Civil Liberties Litigation: The Law of Section 1983 (2025 edition)(2026 edition forthcoming)(West/Westlaw).
Pending Supreme Court Rooker-Feldman Decision: T.M. v. University of Maryland Medical System
The Rooker-Feldman Background
In the circuits, despite the broad jurisdictional grants of 28 U.S.C. §§1331 and 1343 over section 1983 claims, there are circumstances where federal jurisdiction is thought to be absent. Thus, under the Rooker-Feldman doctrine (named after two Supreme Court cases), as subsequently elaborated by the Court in Exxon Mobil Corp. v. Saudi Basic Industries Corp., 544 U.S. 280, 125 S. Ct. 1517, 161 L. Ed. 2d 454 (2005). federal courts have no subject matter (or appellate) jurisdiction over state court judgments in connection with modifying or vacating them. In other words, plaintiffs who are state court losers cannot use section 1983 claims brought in federal court to try to challenge adverse state court decisions directly. That is what state appellate courts are for.
For Rooker-Feldman to apply, then, there must be a state court judgment. Rooker-Feldman does not apply, though, to oust federal courts of jurisdiction where an unreviewed administrative order is involved. This is so even where the administrative agency acted in an adjudicative capacity or where the plaintiff could have sought review, but did not, of the agency’s decision in state court.
Exxon-Mobil Corp. and the Court’s Attempt to Explain the Proper Scope of Rooker-Feldman
In Exxon Mobil Corp., a unanimous 2005 decision, the Supreme Court, per Justice Ginsburg, observed that Rooker-Feldman “has sometimes been construed to extend far beyond the contours of the Rooker and Feldman cases, overriding Congress’ conferral of federal-court jurisdiction concurrent with jurisdiction exercised by state courts, and superseding the ordinary application of preclusion law pursuant to 28 U.S.C.A. 1738.” After extensive analysis of the doctrine, the Court then declared:
“The Rooker-Feldman doctrine, we hold today, is confined to cases of the kind from which the doctrine acquired its name: 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. Rooker-Feldman does not otherwise override or supplant preclusion doctrine or augment the circumscribed doctrines that allow federal courts to stay or dismiss proceedings in deference to state-court actions.”
The Court in Exxon Mobil went on to emphasize that when there is parallel state and federal litigation, as in the case before it, Rooker-Feldman was not triggered just by the entry of judgment in the state court proceeding. Rather, preclusion law would then be applicable. Accordingly, the Court reversed the Third Circuit which had ruled in erroneous reliance on Rooker-Feldman that the district court’s jurisdiction terminated once the state court entered judgment. The Court pointed out that the litigant in the federal action was not seeking to overturn the state court judgment.
Rooker-Feldman turns out to be quite a complicated and arcane doctrine, as you see. I cover it extensively, and collect many circuit court cases, in §§ 1:25-1:30 of my Treatise, Civil Rights & Civil Liberties Litigation: The Law of Section 1983 (2025-26 ed.)(West/Westlaw).
Does Rooker-Feldman apply where a state court decision is not final but is being appealed within the state court system? That is the question currently pending before the Supreme Court.
Certiorari Granted in T.M. v. University of Maryland Medical System
The Supreme Court granted certiorari in a Fourth Circuit case, T.M. v. University of Maryland Medical System, 139 F.4th 344 (4th Cir. 2025), cert granted, 147 S. Ct.— (12-5-25)(No. 25-197), to deal with the following Question Presented: “Whether the Rooker-Feldman doctrine can be triggered by a state-court decision that remains subject to further review in state court.”
In this case, a patient and her parents sought to invalidate a state court’s consent order basing her release from involuntary commitment on compliance with certain conditions. The Fourth Circuit ruled that the district court correctly dismissed this section 1983 complaint under Rooker-Feldman, pointing out that the case “bears an uncanny resemblance to Rooker” which similarly sought to undo a state court judgment.
According to the Fourth Circuit, it did not matter that this case involved a consent order which was itself challenged as unconstitutional; the plaintiff was still a state court loser. And even though plaintiff had won in one state court, that case did not involve the court order that plaintiff now argued was unconstitutional.
Finally, the Fourth Circuit rejected the plaintiff’s argument that Rooker-Feldman should not apply here because there was no final state court judgment. The court explained: “[W] agree with the Sixth and Eighth Circuits that Rooker-Feldman is not limited to situations when a federal court plaintiff no longer has any recourse within the state system.” There was no “stealth fifth requirement for invoking the Rooker-Feldman doctrine.”
Prediction
My prediction is that the Court will affirm the Fourth Circuit and attempt once again, as it did in Exxon-Mobil over twenty years ago, to clarify the scope of Rooker-Feldman. Whether it will succeed this time remains to be seen.
UPDATE
As predicted, the Supreme Court, on June 18, 2016, affirmed the Fourth Circuit. 147 S. Ct. — (2026). Justice Sotomayor wrote for the Court, with Justice Thomas concurring and Justice Barrett, joined by Chief Justice Roberts and Justices Kagan and Gorsuch, dissenting. My next post will deal with this new decision.
Nahmod Law 