A Baltimore hospital held a woman against her will for several months, while a psychiatrist repeatedly tried to forcibly inject her with antipsychotic medications—even as two independent experts concluded she showed no signs of psychosis and didn’t need inpatient care. The Supreme Court will soon decide if her lawsuit against the hospital can continue in federal court.
“T.M.” suffers from a rare medical condition involving Hashimoto’s thyroiditis and non-celiac gluten sensitivity where any amount of gluten could trigger a psychotic episode. In 2023, she arrived at the Baltimore Washington Medical Center asking for voluntary admission after experiencing a gluten-induced psychosis. Hospital staff denied T.M.’s request, opting to involuntarily commit her instead without notifying her father, who was responsible for making health care decisions for T.M. when she was unable to. T.M. was not accused of criminal action, nor was she a danger to herself and others. However, the doctor in charge of her care “speculated that, should they release her from her involuntary detention, she would disregard her medications and wind up back in the hospital,” says the court docket.
After receiving approval from an administrative judge to involuntarily commit T.M., Thomas Cummings, a psychiatrist at the hospital, obtained approval to forcibly inject the plaintiff with antipsychotic medications. T.M. was forced to stay in the hospital against her will and take medicine against the advice of her regular care provider.
Despite passing evaluations from outside psychiatrists, she remained at the hospital involuntarily until June, when she signed a state court consent order allowing her to be released. The order stipulated that she switch care providers, not sue the hospital, and return for regular injections. Her parents were also required to notify the authorities if she didn’t take her new medication. After asking the state appellate court to lift the consent order, T.M. filed a federal lawsuit, which argued that she entered into the consent order under duress and that it “imposes clearly unconstitutional limits on [her] ability to control her own healthcare forever,” making it “invalid, unconstitutional, and unenforceable.” As the federal suit moved forward, T.M. requested a stay in state court until her federal case was resolved.
The U.S. District Court for the District of Maryland dismissed T.M.’s suit under the Rooker-Feldman doctrine, which stipulates that lower federal courts do not have the jurisdiction to review final decisions issued by state courts. The district court argued that, because T.M. stayed her state appeal, the consent order was sufficiently final and she was “a ‘statecourt loser.'”
“Because her relief lies in the state courts,” District Judge Stephanie A. Gallagher wrote, “she cannot avoid Rooker-Feldman simply by bypassing those courts.”
T.M., who argued that her case was pending further review in state courts (and thus still active), appealed Gallagher’s decision to the 4th Circuit Court of Appeals. In June 2025, the circuit court upheld the lower court’s ruling, effectively barring T.M. from challenging the constitutionality of the consent order in federal court. Once again she appealed, this time to the Supreme Court, which agreed to take her case. The question before the Court, which will hear oral arguments on April 20, is whether Rooker-Feldman can be triggered by a state court decision that remains subject to further review.
The Constitutional Accountability Center, a D.C.-based think tank, argues it can’t.
“The Supreme Court has never applied the Rooker-Feldman doctrine in a case like this one, where the state-court judgment is still subject to further review in the state court system,” the group wrote in a blog post. The organization, which filed an amicus brief on behalf of T.M., argues that the doctrine was supposed to apply narrowly to “final decisions of state courts of last resort.” Any expansion beyond this scope “would be completely at odds with the history of Congress’s effort to throw open the doors of the lower federal courts for the vindication of federal rights. Because there was no final judgment of a state court of last resort in T.M.’s case, Rooker-Feldman does not apply [and] the lower federal courts have jurisdiction to hear her case.”
If the Court rules in T.M.’s favor, she will have a chance to try again in federal court to overturn the consent order, rather than being shackled to it for life.
