Supreme Court to Decide Limits on Federal Review of State Court Orders
The Supreme Court will review T.M. v. University of Maryland Medical System Corp. to clarify federal review limits.
Why it matters: The Court’s ruling could redefine when federal courts can intervene in state court decisions, affecting how litigants challenge state court judgments and shaping federalism's boundaries.
- T.M. was involuntarily committed in Maryland in 2023 and challenged her treatment and conditions of release in federal court.
- Both district and appellate courts dismissed her federal suit under the Rooker-Feldman doctrine, citing lack of jurisdiction.
- The Supreme Court will decide if federal review is barred when state court decisions remain subject to further state review.
- Oral arguments are set for April 20, 2026.
The Supreme Court is set to address a pivotal jurisdictional question in T.M. v. University of Maryland Medical System Corporation—specifically, whether the federal Rooker-Feldman doctrine blocks federal courts from reviewing state court decisions that are not yet final and can still be appealed within the state system.
T.M., a minor, was involuntarily committed to a Maryland hospital in 2023 after a psychosis episode. After being subject to a consent order in state court mandating her release under certain conditions, she filed a federal lawsuit, arguing that the consent order was unconstitutional and secured under duress. Both the U.S. District Court for the District of Maryland and the Fourth Circuit rejected her federal claims, invoking the Rooker-Feldman doctrine as a jurisdictional bar.
The Fourth Circuit held on June 4, 2025, that T.M. sought to overturn a state court judgment, fitting squarely within the doctrine's parameters. However, the Supreme Court has noted—most pointedly in Exxon Mobil Corp. v. Saudi Basic Indus. Corp.—that Rooker-Feldman applies to "state-court losers complaining of injuries caused by state-court judgments rendered before the district court proceedings commenced." Notably, as the Constitutional Accountability Center observed, "The Supreme Court has never applied the Rooker-Feldman doctrine in a case like this one, where the state-court judgment is still subject to further review in the state court system."
The justices granted certiorari on December 5, 2025, and will hear oral arguments on April 20, 2026. Their decision will have significant implications for the balance between state and federal court authority—and for litigants seeking to challenge state court rulings in federal court.
By the numbers:
- 2023 — Year T.M. was involuntarily committed.
- June 4, 2025 — Fourth Circuit affirmed district court's dismissal.
- December 5, 2025 — SCOTUS granted certiorari.
- April 20, 2026 — Oral arguments scheduled.
Yes, but: The Supreme Court has yet to address whether Rooker-Feldman applies when state court decisions are still under state review, potentially limiting the doctrine's reach.
What's next: Oral arguments are scheduled for April 20, 2026, with a Supreme Court decision expected by summer 2026.