Author

Justice Sotomayor

Synopsis

Joined By

Justice Alito

Justice Kavanaugh

Justice Jackson

Concurred

Justice Thomas

Synopsis

Dissent

Justice Barrett

Synopsis

Joined By

Chief Justice Roberts

Justice Kagan

Justice Gorsuch

Synopsis

Majority Opinion — Justice Sotomayor

The Supreme Court held that the Rooker-Feldman doctrine bars federal district courts from hearing cases in which state-court losers seek review and rejection of state-court judgments, even when those judgments are still subject to appeal in state court. The case involved T. M., who was involuntarily committed to a psychiatric facility and later entered into a consent order in state court to secure her release. Ten days after the consent order was entered, she filed a federal lawsuit asking the district court to declare the consent order unconstitutional and unenforceable. The Court found this was a classic attempt to have a federal trial court review and overturn a state-court judgment—exactly what Rooker-Feldman prohibits.

The majority, written by Justice Sotomayor, rejected T. M.'s argument that Rooker-Feldman should apply only when a state-court judgment has become final in the highest state court (the kind of judgment the Supreme Court itself can review under 28 U.S.C. §1257). The Court explained that the doctrine rests on two foundations: first, that asking a federal district court to reverse a state-court judgment is an exercise of appellate jurisdiction, which district courts do not possess; and second, that only the Supreme Court has been given appellate jurisdiction over state courts. Adopting T. M.'s rule, the Court reasoned, would undermine federalism by letting federal trial courts second-guess state-court judgments while state appeals are still ongoing, would produce arbitrary results depending on when a federal suit is filed, and would add new complexity without solving existing confusion about the doctrine. The practical effect is that state-court losers cannot circumvent Rooker-Feldman simply by filing in federal court before their state appeal concludes.