Rooker-Feldman Bars Federal Review of State Court Consent Orders

Introduction

In T.M. v. University of Maryland Medical System Corp., No. 24-1707 (4th Cir. June 4, 2025), the Fourth Circuit addressed whether the Rooker-Feldman doctrine precludes a federal district court from entertaining a challenge to a Maryland state‐court consent order.

Background & Parties:

Plaintiffs: T.M., a patient involuntarily committed and subject to forced injections of antipsychotic medication; her parents, J.M. and A.M., who were bound by certain speech-related conditions in the order.
Defendants: University of Maryland Medical System Corporation; Baltimore Washington Medical Center, Inc.; certain hospital officers and clinicians; a private therapy provider; and the county crisis-intervention team.

Key Issues:

Does Rooker-Feldman deprive the federal district court of subject-matter jurisdiction over T.M.’s challenge to a state-court consent order?
Do the parents state a valid claim, e.g., under the First Amendment, against enforcement of conditions placed on them by the same order?

Summary of the Judgment

The Fourth Circuit, in an opinion by Judge Heytens (joined by Judges Wynn and Richardson), held:

T.M.’s Claims: Dismissed for lack of subject-matter jurisdiction under Rooker-Feldman. The court affirmed in part, vacated the district court’s “with prejudice” dismissal, and remanded with instructions to dismiss T.M.’s claims without prejudice.
Parents’ Claims: Dismissed for failure to state a claim on which relief can be granted; the district court correctly observed that the complaint did not plead any cognizable First Amendment violation by the consent order.

Analysis

1. Precedents Cited

Rooker v. Fidelity Trust Co. (1923) & Feldman (1983) – Established that federal district courts lack appellate jurisdiction to reverse or enjoin state-court judgments.
Exxon Mobil Corp. v. Saudi Basic Industries Corp. (2005) – Clarified that Rooker-Feldman is not a broad preclusion doctrine but is confined to four requirements: state-court loser, injury from a state-court judgment, judgment rendered before federal suit, and invitation to review/reject that judgment.
Thana v. Board of License Comm’rs (2016) & Jonathan R. by Dixon v. Justice (2022) – Show Fourth Circuit’s post-Exxon reluctance to invoke Rooker-Feldman; nonetheless, this decision marks the first published invocation since Exxon.
Circuits Split Over Consent Orders: The Seventh Circuit in Johnson v. Orr (2008) held that consent orders are “judgments” for Rooker-Feldman purposes; this Fourth Circuit panel endorsed that view.

2. Legal Reasoning

Applying Exxon’s four-part test, the court found:

State-Court Loser: T.M. lost with respect to the consent order, which is a judgment transforming private agreement into enforceable judicial command.
Injury from Judgment: The complaint pleads injury “‘caused by’” the consent order—forcing medication, controls on her liberty—and requests its invalidation.
Timing: The district suit was filed after the consent order was entered in state court.
Invitation to Review and Reject: T.M. expressly prayed for a declaration that the order is “void ab initio” and an injunction barring its enforcement.

Because all four conditions were met, Rooker-Feldman barred the district court’s jurisdiction.

The court rejected T.M.’s arguments that:

The consent order was not a “final” state-court judgment; the Fourth and Fifth Circuits’ dicta to that effect were deemed non-binding, and the statute conferring Supreme Court jurisdiction (28 U.S.C. § 1257) does not grant lower courts anything.
The suit was really against the medical center’s conduct or state administrative acts; the live complaint sought only to enjoin the consent order itself.
An alleged duress claim targeted “the process” of obtaining an order rather than the order; the complaint’s relief requests made clear the order was the target.

3. Impact

This decision:

Affirms that consent orders are state-court judgments for Rooker-Feldman purposes.
Warns litigants that any attempt to invalidate or enjoin a state-court consent judgment in federal district court will face a threshold jurisdictional bar.
Provides guidance on pleading duress or forced-consent arguments: relief must target non-judicial conduct if litigants wish to avoid Rooker-Feldman.
Limits the scope for peripheral challenges (e.g., against non-parties) absent proper pleading of a cause of action.

Complex Concepts Simplified

Rooker-Feldman Doctrine: A jurisdictional rule preventing federal district courts from acting as appellate tribunals over state-court judgments.
Consent Order: A court order entering into the record an agreement between parties, which then operates with the force of any other judicial decree.
Subject-Matter Jurisdiction: The authority of a court to hear a case; under Article III and federal statutes, district courts have original—but not appellate—jurisdiction over state judgments.
Exxon’s Four Requirements: (1) state-court loser, (2) injury from the judgment, (3) judgment entered before federal filing, and (4) invitation to review/reject it.

Conclusion

T.M. v. University of Maryland Medical System Corp. is a landmark Fourth Circuit ruling reaffirming and clarifying the narrow but potent scope of the Rooker-Feldman doctrine. By holding that even state-court consent orders qualify as judgments that cannot be undone in federal district court, the court reemphasized the proper boundary between state and federal judicial authority. Litigants seeking to challenge non-judicial conduct must frame their federal suits accordingly—and not disguise assaults on state judgments as independent federal claims.