Litigants who lose in state courts are often tempted to sidestep the state's appellate process and ask the federal courts to intervene. But the Rooker-Feldman doctrine prevents that shortcut, prohibiting federal district courts from exercising appellate review over state court judgments. In T.M. v. University of Maryland Medical System Corp. et al., No. 25-197, the Supreme Court resolved a circuit split and underscored the reach of this doctrine, holding that Rooker-Feldman prohibits federal review of state court judgments even if the state appellate process has not yet been exhausted. This holding confirms that litigants who wish to appeal adverse state court judgments must follow, not circumvent, the state's prescribed appellate process.
Rooker-Feldman Prohibits Federal District Courts from Overturning State Judgments
The Rooker-Feldman doctrine preserves the barrier between the state and federal judicial systems. The doctrine instructs that "state-court losers" may not file suit in federal district court to "review and reject[]" a state court judgment. It rests on two distinct but complementary ideas. First, because federal district courts generally lack appellate jurisdiction, they cannot review or overturn decisions of another court. Second, because federal law gives only the Supreme Court jurisdiction to reverse or modify state supreme court judgments, other federal courts lack that power. By limiting federal oversight of the state courts, Rooker-Feldman ensures that state courts maintain their authority over state law issues, preserving the independence and integrity of the state decision-making process.
Though the Rooker-Feldman doctrine has been recognized for decades, the federal courts have struggled to apply it. Recently, courts of appeal had become divided about whether Rooker-Feldman applies to state court judgments that could still be appealed within the state judicial system. Five circuits limited Rooker-Feldman to final judgments by the state's highest court, reasoning that the doctrine applies only when state court proceedings have ended and the Supreme Court has exclusive jurisdiction to hear further appeals. But two circuits instead held that the doctrine applies even if the state court judgment could still be appealed, reasoning that federal district courts have no relevant appellate jurisdiction at all. As the circuit split deepened, the issue became poised for Supreme Court review.
The Supreme Court Holds That Rooker-Feldman Applies Even if State Appeals Are Available
In 2023, T.M. was involuntarily admitted to Baltimore Washington Medical Center after experiencing a psychotic episode triggered by gluten intake. In May 2023, she filed a petition in Maryland state court alleging that her involuntary commitment was unlawful. And in June 2023, the judge entered a consent order providing for T.M.'s release, which formalized conditions she had negotiated with the hospital. T.M. then challenged the consent order in federal district court, alleging that it was entered under duress and was unenforceable, unconstitutional, and void. But the district court dismissed the case sua sponte, holding that the Rooker-Feldman doctrine barred her claims because the consent order was a state court judgment. The Fourth Circuit affirmed, and the Supreme Court granted certiorari to determine whether the doctrine applies when the state court judgment could still be appealed through the state's appellate process. The Supreme Court affirmed and answered the question directly: "It does."
Writing for a 5-4 majority, Justice Sonia Sotomayor reiterated that Rooker-Feldman prevents federal courts from exercising de facto appellate review of state court judgments. Though the Rooker-Feldman doctrine is "narrow," Justice Sotomayor explained, it prevents "state-court losers" from filing federal suits seeking to invalidate a state court judgment, as an appellate court would. And T.M.'s suit did exactly that: in filing a federal action challenging the June 2023 consent order, she was asking a federal district court to overturn the state court's decision. Because that suit was tantamount to an appeal of the state court's consent order, it fell squarely within Rooker-Feldman's "narrow" limits.
T.M. urged the Supreme Court to adopt the majority view among the federal circuits and hold that Rooker-Feldman applies only once the state's highest court has decided the issue. But the majority rejected that notion, observing that "lower federal courts possess no power whatever to sit in direct review of state court decisions." This decision, the majority emphasized, merely "leaves the doctrine as it found it," without expanding its reach or restricting its application. Restricting the doctrine to state supreme courts would "create anomalous outcomes" based on where the case was filed and impair "the 'cooperation and comity' on which our federal system is built." And that would motivate litigants to engage in gamesmanship by filing a federal case before exhausting state-level appeals.
Implications for Litigants
The decision has important implications for litigants involved in parallel or sequential state and federal proceedings. By reaffirming the original understanding of Rooker-Feldman, the Court has underscored that an unfavorable state court judgment cannot, itself, be subsequently challenged in federal court. This clarification should reduce post-judgment forum-shopping and strategic, duplicative filings. For litigants who have received state court judgments in their favor, the rule makes it easier to dismiss collateral federal actions seeking to set those judgments aside.
For litigants on the wrong side of those decisions, the decision confirms that they must seek redress in the state courts of appeal and, eventually, the Supreme Court.
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The authors thank Mary S. Milligan, a summer associate in our Washington, DC office, for her assistance in writing this article.