Supreme Court Reaffirms Limits of Federal Review: Rooker-Feldman Doctrine Bars State-Court Appeals in Federal District Courts

The Supreme Court’s decision in T.M. v. University of Maryland Medical System attempts to bring some clarity to the Rooker-Feldman doctrine, holding that federal trial courts cannot review cases brought by state-court losers complaining of injuries caused by the state-court judgment, regardless of whether the case has completely worked its way through the highest court in that state. In a 5-4 decision, the divided Court “leaves the [Rooker-Feldman] doctrine as it found it” in holding that federal district courts may not review state-court decisions even if the “state court loser” has not yet exhausted its state court appeals.

The Rooker-Feldman doctrine is derived from two cases: Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923) and District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (1983). Justice Sotomayor’s majority read these two cases together (as well as their modern counterpart, Exxon Mobil Corp v. Saudi Basic Industries, Corp., 544 U.S. 280, 284 (2005)) to stand on two jurisdictional premises: first, that federal district courts have “original jurisdiction of all civil actions raising federal questions,” citing 28 U.S.C. § 1331, and second, that the U.S. Supreme Court is the “only federal court with appellate jurisdiction to review state court judgments,” citing 28 U.S.C. § 1257(a). The majority concluded that the Rooker-Feldman doctrine was the natural consequence of taking these premises together because “in asking federal courts of first instance to review and reverse unfavorable state court judgments, the [state-court losers] are seeking an exercise of appellate jurisdiction,” and federal district courts are excluded from exercising appellate jurisdiction under 28 U.S.C. § 1257(a).

Applying these principles, the majority found that the Rooker-Feldman doctrine bars federal district courts from hearing cases that are still working their way through the state court system, because what the state-court loser effectively seeks in federal court—appellate review—is the same whether a state-court appeal is pending or not. Even if the state-court loser has not exhausted its available appeals through the highest court in that state, by filing for review in the federal district court, the state-court loser nonetheless asks the federal district court for an exercise of appellate jurisdiction, which is not a power the federal district courts have under 28  U.S.C. § 1257 (absent an explicit exception, such as federal habeas relief or reviewing an agency decision).

Justice Sotomayor’s opinion was joined by Justices Alito, Kavanaugh, Jackson, and Thomas. Justice Thomas wrote separately to “explain why Rooker, properly understood, is correct as an original matter;” although he joined the majority opinion “in full,” Justice Thomas provided a historical basis for why the majority’s two premises were true: “first, to reverse or modify the allegedly erroneous judgment of another court is to exercise . . . appellate jurisdiction” and second, “only this Court has appellate jurisdiction over state court judgments.” (internal quotations omitted).

The dissent, led by Justice Barrett and joined by Chief Justice Roberts, Justice Kagan, and Justice Gorsuch, disagreed that the Rooker-Feldman doctrine derives from the two premises described by the majority. Instead, they justify the doctrine as “a negative inference from 28 § U.S.C. 1257”: “because Congress gave this Court appellate jurisdiction over certain state-court judgments, district courts must lack jurisdiction to entertain a collateral attack against those judgments.” (Barrett, J., dissenting). According to the dissent, this “negative inference” does not address instances left open by 28 U.S.C. § 1257: state-court judgments that are not issued by the highest court in a particular state, and thus may not be limited to review by the U.S. Supreme Court (potentially leaving the door open for federal district courts’ jurisdiction). The dissent does not address the majority’s criticism that seeking “appellate review” inherently invokes appellate jurisdiction, which 28 U.S.C. § 1257 prohibits for federal district courts. Instead, the dissent points to passing language in the Exxon Mobil decisions referring to applying the doctrine only when state-court litigation “ends;” the dissent argues that because a state case that still has state appellate avenues available has not “ended,” Rooker-Feldman wouldn’t apply.

The Court’s decision makes clear that the status of a challenged state-court judgment (whether it is a final decision from the state’s highest court or subject to further state appellate review) is irrelevant in determining whether a federal district court can weigh in. In either circumstance, a federal district court cannot get involved.