The justices on Monday will hear argument in T.M. v. University of Maryland Medical System Corporation about the circumstances in which lower federal courts may review state-court judgments. The case highlights persistent confusion over lower court jurisdiction, which the justices tried – apparently unsuccessfully – to resolve just over two decades ago.
The current dispute began in March 2023, when a Maryland woman, identified only as T.M., experienced a psychotic episode that she believes stemmed from accidentally consuming gluten. Seeing that she was aggravated and unwell, police escorted her to Baltimore Washington Medical Center.
Because T.M. was already in treatment for what her personal doctor and family had determined to be a rare gluten sensitivity causing changes in one’s mental state, T.M. and her father asked for her admission at the medical center to be voluntary, which would give her more control over her release. But “[h]ospital staff diagnosed [T.M.] with schizophrenia and concluded that involuntary admission would best ensure her safety.” Under Maryland law, individuals who are involuntarily committed are entitled to an administrative hearing. After a hearing on T.M.’s condition, an administrative law judge sided with the hospital, requiring her to remain admitted.
Over the next month, as her involuntary hospital stay continued, T.M. challenged the hospital’s treatment of her in state and federal courts, “[s]eeking to avoid forcible injection” of antipsychotic medication “and secure her release from involuntary commitment.” Most relevant to the Supreme Court case is a petition that she filed in Maryland state court on May 5, 2023, alleging that her forced hospital stay was unlawful.
While her state petition was pending, T.M., her family, hospital staff, and attorneys worked toward a settlement agreement laying out the conditions under which T.M. could be released. In June 2023, the state judge assigned to the case entered the settlement agreement as a consent order. It “provided for T.M.’s immediate release from the medical center but required her to switch psychiatrists, continue taking medication prescribed by the hospital, and dismiss with prejudice her other lawsuits against the medical center and its employees.”
Although T.M. was released, a new legal battle was about to begin. Later in June 2023, she filed a federal lawsuit against the medical center, the University of Maryland Medical System, and leaders of those institutions over the consent order, asking for it to be declared unconstitutional and unenforceable. She also appealed the order within the state court system, to that state’s intermediate appellate court.
Just over a year later, in July 2024, the U.S. District Court for the District of Maryland dismissed T.M.’s federal lawsuit. It held that, under a legal principle known as the Rooker-Feldman doctrine, it could not review her request for relief from the consent order, which was a state-court judgment. As the district court noted, that doctrine, which gets its name from two past Supreme Court rulings on the relationship between state and federal courts, limits the power of lower federal courts. Specifically, it bars them from hearing cases brought by plaintiffs who lost in state court and who are complaining of “injuries” caused by the state-court judgment when that judgment “became final before the proceedings in federal court commenced” and when the plaintiffs are asking the federal court to undo that judgment.
The Supreme Court articulated those boundaries in a third case called Exxon Mobil Corp. v. Saudi Basic Industries Corp. In that 2005 case, the court emphasized that Congress had given the power “to exercise appellate authority ‘to reverse or modify’ a state-court judgment” only to the Supreme Court. The lower courts, Justice Ruth Bader Ginsburg wrote, had been applying the Rooker-Feldman doctrine too broadly by, for example, refusing to continue with a case once a state court had ruled on a related matter. While such state court rulings certainly can affect parallel federal litigation, Ginsburg acknowledged, “federal jurisdiction over an action does not terminate automatically on the entry of judgment in the state court.”
But, as the U.S. Court of Appeals for the 4th Circuit put it in T.M.’s case, “[t]o say that few claims warrant dismissal under the Rooker-Feldman doctrine is not to say that none do.” Rather, that doctrine still applies when a case was: “[1] brought by state-court losers [2] complaining of injuries caused by state-court judgments [3] rendered before the district court proceedings commenced and [4] inviting district court review and rejection of those judgments,” the 4th Circuit said, quoting Exxon. The 4th Circuit therefore affirmed the district court’s decision to dismiss, holding that T.M.’s case satisfied these conditions because (1) the consent order amounted to a loss in state court for T.M.; (2) in asking the federal courts to block the consent order, T.M. sought relief from that judgment; (3) the consent order was in place before the federal lawsuit was filed; and (4) the lawsuit was aimed at undoing the consent order.
T.M. came to the Supreme Court in August, asking the justices to decide whether the Rooker-Feldman doctrine applies when a state-court decision is not final, meaning it “remains subject to further review in state court.” She highlighted a disagreement between federal courts of appeals on that question, noting that, unlike the 4th Circuit, some would have held that her federal lawsuit could move forward because her state case is still in the Maryand intermediate appellate court. In December, the justices agreed to weigh in.
In her brief on the merits, T.M. emphasized that both the Rooker and Feldman cases involved a “final judgment of a state court of last resort.” And the federal statute that serves as the statutory basis of those decisions, she continued, refers to “[f]inal judgments or decrees rendered by the highest court of a State in which a decision could be had.” “To the extent that any negative inference can be drawn from” the statute’s language, T.M. wrote, “it is only that a district court cannot exercise jurisdiction over a final judgment of the highest available state court,” not “non-final judgments” of any state court.
The hospital, medical system, and affiliated parties questioned the logic of that argument in their own merits brief. Why, they asked, would lower courts have the authority to “interfere[] with ongoing state-court proceedings” if the Supreme Court itself cannot do that? “If this Court must wait for the state appellate process to play out before reviewing state-court judgments, surely district courts cannot cut in line to review them first,” the brief said. Such line-cutting would undermine the authority of state courts, according to the brief, and lead to potential fights between state and federal courts for control of a particular case.
T.M. agreed that the Supreme Court does not have jurisdiction over state-court judgments that “remain[] subject to further review and may still be reversed, vacated, or modified in a state proceeding.” But the court shouldn’t assume that, in imposing this limit, Congress “intended implicitly to withhold related jurisdiction from district courts.” The relevant federal statute does not “provide any support for that approach,” she argued, and to hold otherwise would only deepen the confusion surrounding the Rooker-Feldman doctrine. Nevertheless, “[i]f the choice is between expanding the doctrine” to include non-final state-court judgments “or retiring it, the Court should take the latter course,” T.M. wrote.
The hospital, health system, and affiliated doctors countered that T.M. has it backwards, presenting their position as the less complicated of the two. T.M.’s “approach would require extensive litigation over whether state-court proceedings are sufficiently final, a question that already vexes courts on her side of the split.”
Expect those competing claims about the potential consequences of the court’s eventual ruling – and whether these are overblown or of serious concern – to play a major role in Monday’s argument. That ruling is expected by early July.
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