The Supreme Court ruled today that federal district courts lack jurisdiction to hear challenges to state-court judgments that are subject to further review in state appellate proceedings. The ruling applies the Rooker-Feldman doctrine to those state-court judgments, and thus limits the power of federal district courts to weigh-in on state-court cases that haven’t fully run their course in the state courts.
The case, T.M. v. University of Maryland Medical System, arose when T.M. sought to challenge a consent order entered by a state court in federal district court. The consent order was subject to further appellate review in the state court system. (Indeed, T.M. filed an appeal of the order in the state courts.) Yet T.M. sought to challenge it in federal court.
The Court ruled that the federal court lacked jurisdiction. The Court said that the Rooker-Feldman doctrine, which denies federal district courts jurisdiction over certain state-court decisions that are subject to further review within the state courts, barred the suit. The Court wrote that the Rooker-Feldman doctrine was based on two principles: (1) when plaintiffs seek federal district court review of a state court ruling, “they are seeking an exercise of appellate jurisdiction”; and (2) federal appellate jurisdiction of state-court rulings belongs exclusively to the Supreme Court (and not to lower federal courts). The Court said that the doctrine applied squarely to this case.
The ruling makes it more difficult for state-court litigants to challenge state-court rulings in federal court. The Court today made clear that they now have to exhaust their appeals through the state courts and only then bring an appeal only to the Supreme Court.
Justice Barrett dissented, joined by Chief Justice Roberts and Justices Kagan and Gorsuch. Justice Barrett argued that the Rooker-Feldman doctrine only applied to state-court judgments that are not subject to further state-court appeals, most usually state supreme court rulings. She also took aim at the underlying bases for the doctrine.
Justice Thomas concurred, arguing that there’s an originalist basis for the doctrine.