Docket 25-197
T. M. v. University of Md. Medical System Corporation
DecidedJun 18, 2026
5-4decision
Source: CourtListener.
Federal courts cannot review state court judgments still under appeal in state court
Impact5/10
What it does
The Court held that the Rooker-Feldman doctrine bars a federal district court from hearing a case in which a party asks that court to overturn a state court judgment, even if that judgment is still being appealed in state court. A person who loses in state court cannot bypass the state appeals process by filing a federal lawsuit seeking to void the state court's ruling. The ruling leaves the Rooker-Feldman doctrine exactly as it was — neither expanding nor shrinking it — while resolving a split among federal appeals courts on this specific question.
Who benefits
State courts, whose judgments are shielded from simultaneous federal district court review while state appeals are still in progress. Parties who obtained favorable state court judgments, who cannot be immediately dragged into federal court to relitigate those judgments.
Who is affected
People who receive an adverse state court judgment and want to challenge it in federal district court before exhausting their state appeals. Litigants who believe a state court order violated their federal constitutional rights but have not yet completed the state appellate process.
Practical impact
People who lose in state court and want to challenge that ruling in federal district court must now complete the state appeals process first, regardless of whether the state judgment is technically "final" under the standard that governs U.S. Supreme Court review. Federal district courts must dismiss such cases for lack of jurisdiction even when the state appeal is still pending, meaning litigants cannot pursue parallel federal and state challenges to the same state court order. This resolves a long-standing split among federal appeals courts, creating a uniform national rule on when the Rooker-Feldman doctrine applies.
Majority — Sotomayor
Joined by: Thomas, Alito, Kavanaugh, Jackson
The majority held that the Rooker-Feldman doctrine's core logic — that federal district courts have only "original" jurisdiction (the power to hear new cases) and not "appellate" jurisdiction (the power to review another court's decision) — applies regardless of whether the state court judgment is still being appealed. The Court reasoned that when a party asks a federal district court to declare a state court judgment void or unconstitutional, that party is effectively asking the district court to act as an appeals court over the state court, which only the U.S. Supreme Court is authorized to do. The majority rejected the argument that Rooker-Feldman should be limited to judgments that have reached the state's highest court, finding that prior precedents never imposed that requirement and that the doctrine's reasoning applies equally to lower state court judgments still on appeal. The Court also warned that allowing federal district courts to review state judgments mid-appeal would undermine cooperation between state and federal court systems, encourage parties to rush to federal court while state appeals are pending, and produce arbitrary results depending on the timing of when a federal suit is filed. Finally, the majority declined to address arguments that the Rooker and Feldman cases were wrongly decided in the first place, since that question was not properly before the Court.
Dissent reasoning
The dissent argued that the Court's 2005 decision in Exxon Mobil Corp. v. Saudi Basic Industries Corp. already settled this question by confining Rooker-Feldman to cases where the state court proceedings had fully ended — a feature Exxon specifically identified as present in both original Rooker-Feldman cases. Seven federal appeals courts had read Exxon that way, and the dissent argued they were correct. The dissent also raised deeper doubts about Rooker-Feldman's foundations, arguing that a "collateral attack" on a judgment in a new lawsuit is fundamentally different from an appeal, and that Congress's grant of broad federal question jurisdiction to district courts does not contain a carve-out for cases that challenge state court judgments. The dissent contended that existing legal tools — including preclusion rules, abstention doctrines, and the Full Faith and Credit Act — already handle the situations Rooker-Feldman is meant to address, making the doctrine largely redundant. The dissent further argued that the majority's reliance on "federalism" as a rationale is inconsistent with Exxon, which rejected similar federalism-based reasoning, and is in tension with statutes like 42 U.S.C. §1983, which was specifically designed to allow federal courts to protect people from unconstitutional state court action.
Constitutional question
Does the Rooker-Feldman doctrine — which bars federal district courts from reviewing state court judgments — apply only when the state court judgment is final and from the state's highest court, or does it also apply when the judgment is still being appealed in state court?
Precedent changed
The ruling narrows the reading of Exxon Mobil Corp. v. Saudi Basic Industries Corp., 544 U.S. 280 (2005), rejecting the interpretation adopted by seven circuits that Exxon limited Rooker-Feldman to cases where state proceedings had fully ended.