T. M. v. University of Md. Medical System Corporation, Docket No. 25-197

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A woman forced to take psychiatric medications against her will thought she had found a way out. After signing a settlement agreement to end her case in Maryland state court, she hired a new lawyer and rushed to federal court, hoping a federal judge would declare the state court agreement unconstitutional. In a decision that crosses unusual ideological lines, the Court ruled that once you lose in state court, you cannot simply run to federal court to overturn that decision while your state appeal is still pending. The ruling means millions of Americans may find their only path to federal review is through the Supreme Court itself, a nearly impossible hurdle for ordinary people.

What Happened to T.M.

T.M. has a rare condition where eating gluten triggers psychosis. After accidental gluten exposure in March 2023, she was involuntarily committed to Baltimore Washington Medical Center for three months and given forced antipsychotic injections. A Maryland state court approved a settlement releasing her with the conditions that she had to keep taking medication and drop all legal claims against the hospital.

Ten days later, T.M. hired a new lawyer and filed a federal lawsuit, arguing the settlement was unconstitutional and signed under duress. She also appealed in state court while asking that appeal be paused to avoid conflicting rulings. The federal court dismissed her case without even waiting for her to respond, citing a legal doctrine called Rooker-Feldman that generally prevents federal courts from reviewing state court decisions.

The Core Question

The real issue was simple but important: can you challenge a state court decision in federal court while your state appeal is still ongoing, or must you wait until the state process completely finishes?

T.M.'s lawyers argued the doctrine should only apply after state courts have fully finished their work. Seven federal appeals courts agreed with them. They also pointed out that other legal tools already exist to prevent abuse, making Rooker-Feldman unnecessary.

The hospital disagreed. They argued that federal district courts are trial courts, not appeals courts. Once you lose in state court, they said, federal trial courts have no power to overturn that decision, period. The only federal court that can review state decisions is the Supreme Court.

What the Supreme Court Decided

Justice Sotomayor, writing for five justices, sided with the hospital. The Court ruled that federal district courts cannot hear cases where someone lost in state court and is asking a federal judge to reverse that loss, even if state appeals are still pending.

The majority gave two reasons. First, asking a federal trial court to reverse a state court decision essentially asks it to act as an appeals court, which it cannot do. Second, only the Supreme Court has power to review state court decisions. The majority rejected the argument that other legal tools could handle the same job, noting those tools might not apply when directly challenging a court judgment.

The Court also worried about fairness. Allowing federal courts to review pending state appeals would disrupt the relationship between state and federal courts and encourage losing parties to strategically flee to federal court.

An Unusual Alliance

What makes this case striking is who sided with whom. Justice Sotomayor, considered one of the Court's more liberal members, wrote the majority opinion joined by conservative Justices Thomas and Alito. Meanwhile, Justice Barrett dissented alongside Chief Justice Roberts and Justices Kagan and Gorsuch, a mix that crosses typical ideological lines.

This unusual split suggests the decision turned on how courts should be structured and how federal and state systems should interact, not on familiar political divisions.

Justice Thomas wrote separately to provide historical grounding, arguing that reviewing another court's judgment has always been considered an appellate power, regardless of the legal form used to challenge it.

Federal and State Lawsuits

Under this ruling, if you lose in state court, you cannot file a federal lawsuit challenging that decision while your state appeal is still pending. Your only option is to wait until your state process completely finishes, then ask the Supreme Court to review it. For most people, getting the Supreme Court to hear your case is nearly impossible.

The dissent warned lower courts not to expand this doctrine further, suggesting future battles over its exact boundaries are likely. The unresolved tensions between the majority and dissent mean this issue will return to the Court again.

In plain terms the Supreme Court has reinforced that state courts get the first and last word on state law matters, and federal courts must stay out of the middle.