Today the Supreme Court decided T.M. v. University of Maryland Medical System Corp., a case concerning the application of the Rooker-Feldman doctrine, under which federal district court review of state court decisions is generally barred.
The justices split 5-4 on the application of the doctrine here. Justice Sotomayor wrote for the Court. She summarized the issue in T.M. this way:
Under what has become known as the Rooker-Feldman doctrine, federal district courts lack jurisdiction over "cases brought by state-court losers complaining of injuries caused by state-court judgments rendered before the district court proceedings commenced and inviting district court review and rejection of those judgments." Exxon Mobil Corp. v. Saudi Basic Industries Corp., 544 U. S. 280, 284 (2005). This case asks whether this rule bars suit when the state court judgment at issue is subject to further review in state appellate proceedings. A straightforward application of the logic and reasoning underlying Rooker-Feldman leads to one conclusion: It does. Because this suit falls within the narrow doctrine's limits, the Court of Appeals for the Fourth Circuit properly affirmed its dismissal.
