T.M. v. University of Maryland Medical System Corp.
Decision
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Opinion of the Court
The Facts
T.M., a patient with a medical condition causing altered mental states from gluten exposure, was involuntarily committed to University of Maryland Medical System and a psychiatrist attempted to administer a forced medication injection. T.M. challenged the involuntary commitment and forced medication in federal court, but courts ruled the Rooker-Feldman doctrine barred federal review because state courts had already ruled on the matter.
The Issue
Whether the Rooker-Feldman doctrine bars federal court jurisdiction over claims arising from a state court judgment when the state-court proceedings are not yet final and remain subject to further state court review.
The Rules
Federal district courts lack subject-matter jurisdiction to review final state court judgments; such review is reserved for the Supreme Court via certiorari.
No state shall deprive any person of life, liberty, or property, without due process of law.
The Application
T.M. argues the Rooker-Feldman doctrine does not bar federal jurisdiction when underlying state court proceedings are not yet final. Her federal civil rights claims arise independently from the involuntary commitment and forced medication — they are original claims challenging state actors' conduct, not disguised appeals from a state court judgment.
The hospital argues Rooker-Feldman properly bars T.M.'s federal claims because they are inextricably intertwined with the state court's commitment order. Federal courts cannot serve as an end-run around state judicial proceedings, and T.M.'s claims effectively seek to overturn the state court's determination through a parallel federal action.
Argued April 20, 2026. The case will clarify when the Rooker-Feldman doctrine applies — specifically whether it bars federal claims when state proceedings are ongoing rather than final. The doctrine has been narrowed in recent years, and the Court may further limit its reach to prevent it from swallowing legitimate federal civil rights jurisdiction.
The Conclusion
**The Rooker-Feldman doctrine does not bar T.M.'s federal claims.** The question is whether the federal plaintiff is complaining of injuries caused by a state-court judgment — not whether the claims are "inextricably intertwined" with state proceedings. Affirmed.
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