A divided Supreme Court on Thursday clarified the scope of a doctrine limiting lower federal courts’ authority to review state-court judgments. In an opinion from Justice Sonia Sotomayor in T.M. v. University of Maryland Medical System Corp., the court, by a vote of 5-4, held that the status of a challenged state-court judgment – specifically, whether it is a final decision from the highest court of a state or, instead, “is subject to further review in state appellate proceedings” – is not relevant in determining whether a federal district court can weigh in.
Justice Amy Coney Barrett dissented, in an opinion joined by Chief Justice John Roberts and Justices Elena Kagan and Neil Gorsuch. She argued that Thursday’s opinion leaves an already confusing legal principle “worse off.”
The doctrine in question is the Rooker-Feldman doctrine, which gets its name from two past rulings on the relationship between state and federal courts. The doctrine bars lower federal courts from hearing “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,” as Justice Ruth Bader Ginsburg put it in Exxon Mobil Corp. v. Saudi Basic Industries Corp., a 2005 case in which the court responded to persistent confusion surrounding the doctrine by attempting to clearly define its scope. However, Exxon Mobil left some questions unanswered, including the one that the court took up this term: whether lower federal courts can review a state-court judgment that remains subject to further review in state courts.
That question was brought to the justices by a Maryland woman identified only as T.M., who was involuntarily admitted to the hospital after a psychotic episode. She seeks federal court review of a settlement agreement she reached with the hospital, which outlined the conditions under which she would be discharged. A judge in Maryland entered the settlement as a consent order in a lawsuit that T.M. filed in state court when she was trying to secure her release, and T.M. later appealed the order within the state court system even as she challenged it in federal court.
T.M. contended that the Rooker-Feldman doctrine does not apply to the consent order because it was a non-final judgment, meaning it remained subject to further review in state courts. But a federal district court in Maryland and the U.S. Court of Appeals for the 4th Circuit disagreed, holding that the doctrine bars them from hearing T.M.’s case.
On Thursday, the Supreme Court affirmed the 4th Circuit, holding that a “straightforward application of the logic and reasoning underlying Rooker-Feldman leads to” the conclusion that T.M.’s case cannot move forward in federal court.
To hold that the doctrine only applies to final state-court judgments would require “a reimagining, rather than an application, of the Court’s Rooker-Feldman precedents,” Sotomayor wrote in the 18-page majority opinion. And that “reimagining,” she continued, would “create anomalous outcomes,” because so much would hinge on when the federal suit was filed, and it would also disrupt “the ‘cooperation and comity’ on which our federal system is built.” Moreover, such a holding would lead to more confusion, as “[i]t is not always straightforward to determine whether a given state-court judgment is” truly final.
Sotomayor concluded by observing that “the animating force behind many of T. M.’s and the dissent’s arguments appears to be the belief that Rooker and Feldman were wrongly decided and so should be cabined whenever possible, if not outright overruled.” But the question of whether to overrule the doctrine was not part of the question that the justices agreed to decide and was not raised in T.M.’s petition for review, she wrote, and thus the court declined to consider it.
Justice Clarence Thomas wrote a 14-page concurring opinion in which he essentially defended the Rooker-Feldman doctrine, describing it as “correct as an original matter.” “The power to revise or modify another court’s judgment or decree has been recognized as an exercise of appellate jurisdiction from before the ratification of the Constitution,” he wrote, and federal district courts are not authorized to exercise appellate jurisdiction.
In her 12-page dissent, Barrett painted a contrasting picture of the doctrine, asserting that it “stands on shaky ground,” and also highlighted the court’s effort in Exxon Mobil to keep “its footprint small.” In that ruling, Barrett wrote, the court emphasized that the doctrine stemmed from cases in which “the federal action was brought ‘after the state proceedings ended’” and that the application should be limited to such cases. For that reason, a faithful reading of Exxon Mobil would lead the court “to reject the application of Rooker-Feldman to T. M.’s case,” because state proceedings are still underway. Thursday’s opinion, Barrett continued, “relax[es]” those tight boundaries.
“Still,” Barrett concluded, “the news is not all bad.” While the court did relax the boundaries drawn in Exxon Mobil, “it repeatedly emphasizes” the narrowness of the Rooker-Feldman doctrine. “Courts should not lose sight of that message,” Barrett wrote. “In the end, Rooker-Feldman has been given an inch—it should not be allowed to take a mile.”
