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.
The line-up this decision produced is what is particularly interesting. Justice Sotomayor was joined by Justices Thomas, Alito, Kavanaugh, and Jackson. (Justice Thomas also wrote a separate concurrence, defending Rooker “as an original matter.”)
Justice Barrett dissented, joined by the Chief Justice and Justices Kagan and Gorsuch. Her opinion begins:
Twenty years ago, this Court held that the Rooker-Feldman doctrine is “confined” to the procedural circumstances of the two cases from which the doctrine draws its name. Exxon Mobil Corp. v. Saudi Basic Industries Corp., 544 U. S. 280, 284, 291 (2005); see Rooker v. Fidelity Trust Co., 263 U. S. 413 (1923); District of Columbia Court of Appeals v. Feldman, 460 U. S. 462 (1983). In “both cases,” we emphasized, the federal action was brought “after the state proceedings ended.” Exxon, 544 U. S., at 291. Seven Courts of Appeals took us at our word, refusing to apply Rooker-Feldman when the underlying state action remained pending. They were right to hold the line. Because the Court has chosen to relax it, I respectfully dissent.
Her dissent concludes:
The upshot of today’s decision is that the Court has muddied waters that were hardly clear to begin with. That is unfortunate, because there was a better path available: treating Rooker-Feldman as “the §1257 Rule.” VanderKodde, 951 F. 3d, at 409 (Sutton, J., concurring). Doing so would have been both clearer and more faithful to Exxon.
Still, the news is not all bad. Although the Court expands Rooker-Feldman beyond Exxon‘s line, it repeatedly emphasizes that the doctrine is “narrow.” See ante, at 1, 7, 8, 18. Courts should not lose sight of that message. In the end, Rooker-Feldman has been given an inch—it should not be allowed to take a mile.
T.M. was not the only decision today to produce an interesting lineup. The Court was unanimous in the judgment in United States v. Hemani–a potentially important Second Amendment case–but split on the rationale. Justice Gorsuch wrote for the Court. Justice Alito wrote separately, only concurring in the judgment and was joined by Justice Kagan. (Yes, you read that correctly.) Justices Thomas and Jackson also authored concurring opinions.
