Oral Argument Re-Listen: T.M. v. UMD MSC | Does Rooker-Feldman Bar T.M.'s Lawsuit?

T.M. v. University of Maryland Medical System Corporation | Case No. 25-197 | Docket Link: Here | Argued: April 20, 2026 | Decided: June 18, 2026

Overview: A Maryland woman signed a state-court consent order to secure release from involuntary psychiatric commitment, then challenged that order in federal district court while her state-court appeal remained pending — pushing the limits of the Rooker-Feldman doctrine.

Question Presented: Whether the Rooker-Feldman doctrine bars federal district court jurisdiction over suits challenging state-court judgments that remain subject to further review in state appellate proceedings.

Posture: Fourth Circuit affirmed District Court's dismissal of T.M.'s complaint under Rooker-Feldman for lack of jurisdiction.

Main Arguments:

T.M. (Petitioner):

• (1) Rooker-Feldman applies only after state proceedings end, per Exxon Mobil's confinement to the procedural circumstances of Rooker and Feldman;
• (2) Section 1257 cannot support a negative inference extending the doctrine to non-final state-court judgments;
• (3) preclusion and abstention doctrines adequately address federalism concerns without imposing a blunt jurisdictional bar.

UMD Medical System (Respondent):

• (1) Exxon Mobil's four-element test contains no finality requirement; district courts lack appellate jurisdiction to void state-court judgments regardless of pending state review;
• (2) T.M. satisfies every Rooker-Feldman element — she asked a federal court to declare void a consent order entered ten days before she filed;
• (3) T.M.'s rule spawns parallel duplicative litigation, gamesmanship, and federalism harm that abstention and preclusion fail to prevent.

Holding: The Rooker-Feldman doctrine bars federal district court jurisdiction over suits brought by state-court losers complaining of injuries caused by state-court judgments rendered before the district court proceedings commenced and seeking federal review and rejection of those judgments, regardless of whether the state-court judgment remains subject to further review in state appellate proceedings. Affirmed.

Voting Breakdown: 5-4. Justice Sotomayor delivered the opinion of the Court, joined by Justices Thomas, Alito, Kavanaugh, and Jackson. Justice Thomas filed a concurring opinion. Justice Barrett filed a dissenting opinion, joined by Chief Justice Roberts and Justices Kagan and Gorsuch. Fourth Circuit affirmed.

Opinion: Here

Majority Reasoning:

• (1) T.M.'s finality theory contradicts precedent — Rooker (1923), Feldman (1983), and Exxon Mobil (2005) all rest on a functional distinction between original and appellate jurisdiction, not on section 1257's finality requirement;
• (2) T.M.'s rule produces arbitrary results and invites gamesmanship — identical plaintiffs with different filing timing reach opposite outcomes;
• (3) abstention and preclusion doctrines don't substitute where a plaintiff directly attacks a state-court judgment as the source of injury.

Separate Opinions:

• Justice Thomas concurred in full, writing separately to ground Rooker in constitutional text and Founding history — the power to revise another court's judgment always constituted appellate jurisdiction, and Congress never granted district courts that revising power over state civil judgments.
• Justice Barrett dissented, joined by Chief Justice Roberts and Justices Kagan and Gorsuch. The dissent argued Exxon Mobil confined the doctrine to cases filed "after the state proceedings ended," and the majority expanded a doctrinally shaky rule beyond Exxon's mandate.

Implications:

• (1) State-court losers cannot access federal district court while state appeals remain open — they must exhaust state remedies first;
• (2) The core Rooker-Feldman ambiguity — distinguishing judgment attacks from independent federal claims — survives and drives future litigation;
• (3) T.M. retains a stayed Maryland state appeal and may yet petition the Supreme Court if constitutional questions survive.

The Fine Print:

• 28 U.S.C. § 1257(a): "Final judgments or decrees rendered by the highest court of a State in which a decision could be had, may be reviewed by the Supreme Court by writ of certiorari where the validity of a treaty or statute of the United States is drawn in question..."
• 28 U.S.C. § 1331: "The district courts shall have original jurisdiction of all civil actions arising under the Constitution, laws, or treaties of the United States."

Primary Cases:

• Exxon Mobil Corp. v. Saudi Basic Industries Corp. (2005): Rooker-Feldman doctrine "confined to cases brought by state-court losers complaining of injuries caused by state-court judgments rendered before the district court proceedings commenced and inviting district court review and rejection of those judgments" — the central precedent both sides claimed as support.
• Rooker v. Fidelity Trust Co. (1923): Federal district courts lack jurisdiction to reverse or modify state-court judgments — such relief constitutes an exercise of appellate jurisdiction that Congress vested exclusively in the Supreme Court.

Timestamps:

[00:00:00] Argument Preview

[00:01:15] Oral Advocates

[00:01:27] Argument Begins

[00:01:35] T.M. Opening Statement

[00:03:51] T.M. Free for All Questions

[00:27:56] T.M. Round Robin Questions

[00:42:13] UMD Medical Opening Statement

[00:44:01] UMD Medical Free for All Questions

[00:59:41] UMD Medical Round Robin Questions

[00:59:50] T.M. Rebuttal