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        No. 25-197 · October Term 2025

        T. M. v. University of Md. Medical System Corporation

        Decided June 18, 2026, 5–4 · From the United States Court of Appeals for the Fourth Circuit

        Question

        Can the Rooker-Feldman doctrine, which prevents parties who lose in state courts from challenging injuries caused by state-court judgments, be triggered by a state-court decision that remains subject to further review in state court?

        Facts of the case

        In March 2023, T.M., a woman with a rare medical condition that triggers psychosis upon consuming gluten, was involuntarily committed to Baltimore Washington Medical Center after an episode. Her treating psychiatrist sought and received state approval to forcibly administer antipsychotic medication; T.M. contested this but was unsuccessful in administrative proceedings. Independent psychiatrists later stated that T.M. no longer required inpatient care. To secure her release, T.M. and the hospital negotiated an oral agreement, which was formalized as a state court consent order. The order allowed her to leave the hospital on the condition that she comply with ongoing psychiatric treatment and medications, switch providers, and drop pending lawsuits. Her parents, J.M. and A.M., were also bound to notify authorities if she failed to comply. Ten days later, represented by new counsel, T.M. and her parents filed the present federal lawsuit claiming that the consent order was unconstitutional and entered under duress. They challenged the order as violating T.M.’s due process rights and sought declaratory and injunctive relief invalidating its enforcement. They did not request damages…

        From Oyez.

        Holding

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

        The Court's vote 5–4

        Majority: Sonia Sotomayor, Clarence Thomas, Samuel A. Alito, Brett M. Kavanaugh, Ketanji Brown Jackson

        Dissent: Amy Coney Barrett, John G. Roberts, Elena Kagan, Neil M. Gorsuch