The Supreme Court handed down a 5-4 ruling that defied ideologicial divides on Thursday.
T.M. v. University of Maryland Medical System Corporation.. In this case, questions about the boundary between state and federal judicial power proved more unifying than political philosophy, drawing justices from opposite ends of the spectrum into the same camp despite thosecannot review or overturn state‑court judgments even while those judgments are still being appealed in the state system, leaving that authority solely to the U.S. Supreme Court.
The case was brought by a person identified only as T.M. , who said she has a medical condition that can cause psychosis when she ingests gluten. In March 2023, she accidentally did so and was taken to the emergency room at Baltimore Washington Medical Center, according to court filings. She was allegedly held involuntarily at the hospital despite for about three months despite objections from her and her father, according to court documents.
At that time, the medical center obtained an order authorizing forcible injections of antipsychotic medication. Her parents filed several state and federal lawsuits seeking her release and opposing forced injections. They reached a settlement agreement to facilitate her release, and a state judge presiding over a state habeas petition entered the agreement as a consent order on June 12, 2023. She was then released on several conditions, including that she dismiss with prejudice all pending cases against the facility.
However, 10 days later, she and her parents obtained new counsel and sued them in federal district court, seeking a declaration that the order violated her due process rights. At the same time, she appealed the consent order to the Appellate Court of Maryland.
The District Court dismissed her complaint, ruling it did not have jurisdiction because of the Rooker-Feldman doctrine, a narrow rule stating that federal district courts are not able to act as appellate courts reviewing state‑court judgments; only the Supreme Court is able to do so. Thursday's ruling makes it clear that the doctrine applies even when judgments are being appealed in state courts. A majority of Supreme Court justices rejected the plaintiff’s argument in an opinion written by Sotomayor.
“This case asks whether this rule bars suit when the state court judgment at issue is subject to further review in state appellate proceedings. A straightforward application of the logic and reasoning underlying Rooker-Feldman leads to one conclusion: It does,” she wrote. Sotomayor wrote that the plaintiff’s theory “cannot be squared with this Court’s precedents, which plainly adopted a different, more functional view of original and appellate jurisdiction than what T. M. advances here.
” Those theories require “a reimagining, rather than an application, of the Court’s Rooker-Feldman precedents,” she wrote.
“Ultimately, adopting T. M. and the dissent’s rule would require the Court to abandon a central part of Rooker’s reasoning and reinterpret the doctrine to rest solely on a strict negative inference from §1257,” she wrote. “We appreciate the Supreme Court's careful consideration of this matter and its decision today and are pleased that the Supreme Court justices agreed with our position, which affirms the legal principles and longstanding precedent in this case.
”Conservative Justice Amy Coney Barrett wrote a dissenting opinion and was joined by Chief Justice John Roberts, Neil Gorsuch and liberal Elena Kagan. Barrett wrote that Rooker-Feldman “stands on shaky ground” and that the court has “consciously kept its footprint small. ” “Its rationale has gotten no firmer, so we should make the doctrine no larger,” she wrote.
“Beyond the difficulties of finding a statutory basis for Rooker-Feldman, parts of the United States Code undercut it. The doctrine is in tension, to say the least, with statutes granting district courts jurisdiction in categorical terms. ”
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