Rooker-Feldman Applies to Appealable State Judgments: Federal District Courts Lack Jurisdiction Even While State Appeals Are Pending

Case: T. M. v. University of Md. Medical System Corporation (U.S. Supreme Court, June 18, 2026)  |  Citation: 608/2

1. Introduction

This case arises from intensive, parallel state and federal litigation following petitioner T. M.’s involuntary commitment and an order authorizing forced antipsychotic injections. After negotiating a settlement embodied in a state-court consent order requiring her discharge subject to conditions (including medication compliance and dismissal with prejudice of pending actions), T. M. filed a federal suit ten days later seeking declarations that the consent order was unconstitutional and coerced, and an injunction preventing its enforcement.

The central jurisdictional issue was whether Rooker-Feldman applies only when the state litigation has produced the kind of §1257(a) “final judgment” reviewable in the Supreme Court (i.e., a final judgment rendered by the state’s highest court), or whether it also bars federal district court review when the state judgment is still on appeal within the state system. The Court resolved a circuit conflict (noted against decisions like RLR Invs., LLC v. Pigeon Forge and Federación de Maestros de P. R. v. Junta de Relaciones del Trabajo de P. R.) by adopting the latter view.

2. Summary of the Opinion

Justice Sotomayor, writing for the Court, affirmed the Fourth Circuit’s dismissal for lack of subject-matter jurisdiction. The Court held that Rooker-Feldman applies when a federal plaintiff complains of injuries caused by a state-court judgment rendered before the federal suit commenced and asks the federal district court to declare that judgment void or to enjoin its enforcement—regardless of whether state appellate review is still available or ongoing.

The Court emphasized it was neither expanding nor contracting the doctrine beyond the “narrow ground” described in Exxon Mobil Corp. v. Saudi Basic Industries Corp., but simply applying it to judgments that are not yet final in the §1257 sense.

3. Analysis

3.1 Precedents Cited (and How They Shaped the Holding)

Foundational Rooker-Feldman cases

• Rooker v. Fidelity Trust Co.: The Court treated a federal district-court suit seeking to declare a state judgment “null and void” as an impermissible attempt to “reverse or modify” that judgment—i.e., an exercise of appellate jurisdiction—because “the jurisdiction possessed by the District Courts is strictly original.” In T. M., the Court relied on Rooker’s functional distinction between original and appellate jurisdiction to reject the idea that appeal-pendency in state court changes the analysis.
• District of Columbia Court of Appeals v. Feldman: The Court held that district courts cannot “review” final judicial determinations of a state (or D.C.) high court; review “can be obtained only in” the Supreme Court under §1257. Critically for this case, the majority highlighted Feldman’s footnote rejecting the notion that district court review becomes permissible merely because the Supreme Court lacks §1257 jurisdiction in a given posture—undermining petitioner’s attempt to make §1257 finality the gatekeeper for Rooker-Feldman.

Modern narrowing and articulation of the doctrine

• Exxon Mobil Corp. v. Saudi Basic Industries Corp.: The Court treated Exxon as the controlling articulation of the doctrine’s “narrow ground”: suits by state-court losers complaining of injuries caused by state-court judgments rendered before the federal case commenced and inviting federal “review and rejection.” Here, Exxon supplied the operative test and the “review and rejection” vocabulary; the Court read Exxon as not imposing a requirement that the challenged state judgment be final in the §1257(a) sense.
• Lance v. Dennis: Reinforced that the doctrine applies only in “limited circumstances” where the plaintiff effectively seeks an appeal of an unfavorable state-court decision to a lower federal court. The majority invoked this framing to characterize T. M.’s requested relief as an attempted appeal in substance.
• Reed v. Goertz and Skinner v. Switzer: Cited to mark the boundary between forbidden challenges to an “adverse” state-court decision and permissible challenges to the underlying “statute or rule governing” the decision. T. M. challenged the consent order itself (the judgment), placing her claim on the barred side of the line.

Cases supporting the “functional” appellate-jurisdiction rationale

• Johnson v. De Grandy: Used for the proposition that Rooker-Feldman bars what “in substance” would be appellate review of a state judgment, supporting the Court’s rejection of petitioner’s formal §1257 finality test.
• Verizon Md. Inc. v. Public Serv. Comm'n of Md.: Quoted (via Exxon) for the idea that §1331 grants original jurisdiction but does not authorize district courts to exercise appellate jurisdiction over state-court judgments—bolstering the majority’s insistence that Rooker-Feldman rests on both §1331’s “original” limitation and §1257’s channeling of appellate review to the Supreme Court.
• Atlantic Coast Line R. Co. v. Locomotive Engineers: Provided the broader structural principle that district courts lack “any power to review directly cases from state courts,” reinforcing the federal/state system separation that the doctrine protects.

Federalism/comity and finality principles

• Ruhrgas AG v. Marathon Oil Co.: Cited for the “cooperation and comity” rationale; the majority used it to argue that allowing district-court review during state appeals would undermine federalism.
• Radio Station WOW, Inc. v. Johnson and North Dakota Bd. of Pharmacy v. Snyder's Drug Stores, Inc.: Invoked to explain that §1257’s finality rule serves to minimize federal intrusion into ongoing state matters—supporting the majority’s view that district-court intervention mid-appeal would be especially disruptive.

Why petitioner’s abstention/preclusion alternative did not carry the day

• Younger v. Harris and Colorado River Water Conservation Dist. v. United States: Appeared in the majority’s discussion (and the case’s procedural background) to illustrate that abstention doctrines may not fit suits alleging injuries stemming directly from a judgment itself rather than parallel relitigation. The majority used this uncertainty to justify maintaining Rooker-Feldman as a jurisdictional barrier in the narrow category of “review and rejection” suits.
• Lucky Brand Dungarees, Inc. v. Marcel Fashions Group, Inc.: Cited to describe the limits of issue preclusion (“actually decided” and “necessary to the judgment”), supporting the majority’s skepticism that preclusion doctrines reliably substitute for Rooker-Feldman in judgment-directed challenges.

Circuit-split backdrop (noted to frame the question presented)

• RLR Invs., LLC v. Pigeon Forge: Represented the view (shared by the Fourth Circuit) that Rooker-Feldman can apply even when state review remains available.
• Federación de Maestros de P. R. v. Junta de Relaciones del Trabajo de P. R. (and cases collected like Malhan v. Secretary U. S. Dept. of State, Nicholson v. Shafe, Guttman v. Khalsa, Hoblock v. Albany Cty. Bd. of Elections, Mothershed v. Justices of the Sup. Ct.): These decisions were cited to show other circuits had adopted “ended proceedings” frameworks. The Supreme Court rejected the “state proceedings must have ended” limitation insofar as it prevents applying Rooker-Feldman to judgments still subject to appeal.

Finality complexity (why a §1257-finality test was rejected)

• Market Street R. Co. v. Railroad Comm'n of Cal.: Cited for the two-part notion of §1257 finality, which can be difficult to apply (no further state review; effective determination of the litigation). The Court used this to argue petitioner’s proposed rule would add complexity, not reduce it.
• Cox Broadcasting Corp. v. Cohn: Cited to show the Supreme Court can sometimes review state decisions even when further proceedings remain, illustrating why tying Rooker-Feldman mechanically to §1257 finality would generate additional threshold litigation.

Concurrence’s “original meaning” support

• Justice Thomas’s concurrence recast the doctrine as an elementary structural rule: state-court losers may appeal within the state system (and potentially to the Supreme Court), but not to a federal trial court. The concurrence grounded this in the original/appellate distinction and early constitutional cases like Marbury v. Madison and Ex parte Bollman, reinforcing the majority’s functional conception of what it means to seek appellate review “in substance.”

Dissent’s competing account (and why the majority rejected it)

• Justice Barrett’s dissent argued Exxon confined Rooker-Feldman to cases brought after state proceedings “ended,” and urged treating the doctrine as “the §1257 Rule” limited by §1257 finality. The majority rejected this as inconsistent with Rooker, Feldman, and post-Exxon functional statements (e.g., Johnson v. De Grandy, Lance v. Dennis), and as producing incentives for premature federal filings during state appeals.

3.2 Legal Reasoning

The Court’s reasoning proceeds in three steps:

1. Identify the doctrine’s “narrow ground” (from Exxon Mobil Corp. v. Saudi Basic Industries Corp.): If a plaintiff (i) lost in state court, (ii) complains of injuries caused by the state-court judgment, (iii) challenges a judgment rendered before the federal case began, and (iv) invites the district court to “review and reject” that judgment, the suit is jurisdictionally barred.
2. Apply that test to the complaint: T. M. sought to have the consent order declared “unconstitutional, unenforceable, and void ab initio,” and to enjoin its enforcement—classic “review and rejection” of the judgment itself. The consent order preceded the federal filing by ten days. That placement made this case “the paradigm situation” barred by Rooker-Feldman.
3. Reject petitioner’s proposed “final-highest-court judgment” limitation: The Court held that the doctrine is not merely a negative inference from §1257 finality; rather, it is also grounded in §1331’s grant of original (not appellate) jurisdiction and in the structural separation between state adjudication and federal trial jurisdiction. Allowing district-court review mid-appeal would undercut comity, invite duplicative litigation, and generate timing-based arbitrariness (rewarding plaintiffs who rush to federal court before the state appeal completes).

3.3 Impact

• Closes a “pending appeal” escape hatch: Plaintiffs cannot evade Rooker-Feldman by filing in federal district court while simultaneously pursuing (or keeping available) state appellate review of the same judgment.
• Reinforces jurisdictional sequencing: If the injury is the state judgment itself, the appropriate route is state appellate review (and potentially Supreme Court review where authorized), not a parallel federal district-court challenge framed as constitutional or duress-based invalidity.
• Strategic litigation effects: The decision reduces incentives for “protective” federal filings aimed at obtaining a second forum to invalidate a state judgment while state appellate proceedings continue.
• Doctrinal boundary remains the key battleground: The Court stressed that confusion largely lies in identifying whether the plaintiff seeks “review and rejection.” This opinion does not soften that line; it clarifies only that appeal-pendency does not defeat the doctrine once “review and rejection” is present.

4. Complex Concepts Simplified

• Rooker-Feldman doctrine: A jurisdiction rule: federal district courts generally cannot function as appellate reviewers of state-court judgments. If your claimed injury is “the state-court judgment,” you typically must pursue relief through the state appellate system (and possibly the U.S. Supreme Court), not a federal trial court.
• “Original” vs “appellate” jurisdiction: District courts decide cases in the first instance (“original”). Appellate courts review and correct judgments. Rooker-Feldman treats certain federal complaints as disguised appeals because the requested relief would require the district court to declare the state judgment wrong and void.
• 28 U. S. C. §1331 and §1257(a): §1331 gives district courts original jurisdiction over federal questions. §1257(a) channels Supreme Court review of certain state-court judgments. The majority treats Rooker-Feldman as reflecting both: district courts are not appellate reviewers, and Supreme Court review is the federally authorized appellate pathway for state judgments.
• Consent order: A settlement agreement entered as a court order. Because it is a judgment of the court, attacking its validity in federal district court can amount to attacking the state-court judgment itself.
• Preclusion vs Rooker-Feldman: Preclusion (claim/issue preclusion) is a merits defense about relitigation; Rooker-Feldman is jurisdictional and asks whether the suit is, in substance, an appeal of a state judgment.
• Abstention: Doctrines (e.g., Younger v. Harris, Colorado River Water Conservation Dist. v. United States) sometimes permit or require federal courts to step aside due to ongoing state proceedings. The majority viewed abstention/preclusion as uncertain fits for “judgment-as-injury” suits, supporting a continued jurisdictional bar in the narrow Rooker-Feldman category.

5. Conclusion

T. M. v. University of Md. Medical System Corporation cements a key clarification: once a federal complaint targets a state-court judgment itself and seeks its nullification or non-enforcement, Rooker-Feldman bars federal district court jurisdiction even if the judgment remains appealable and state appellate proceedings are pending. The Court framed the doctrine as a narrow but firm structural boundary preserving the separation between federal trial courts and state appellate processes, while leaving the doctrine’s most litigated question—what counts as “review and rejection”—for future cases.