The Supreme Court’s decision in T.M. v. University of Maryland Medical System Corp. resolves a jurisdictional question that had divided the federal courts of appeals for years: whether the Rooker-Feldman doctrine applies when the state-court judgment being attacked remains subject to appellate review. The Court answered that it does.
Although the case arose from a Section 1983 action challenging a state consent order, its practical significance extends well beyond constitutional litigation. In Florida, the decision is likely to surface most often in foreclosure, probate, receivership, and bankruptcy disputes, where disappointed state-court litigants often ask federal courts to invalidate, enjoin, or otherwise undermine existing state-court rulings.
A brief word about the facts helps frame the holding. After T.M. was involuntarily committed and subjected to forced medication proceedings in Maryland, the parties negotiated a consent order governing her release. Ten days after entry of that order, T.M. filed suit in federal district court seeking declarations that the order violated due process, was entered under duress, and was unenforceable, while simultaneously pursuing appellate relief in the Maryland courts.
The Supreme Court’s reasoning is simple but important. Rooker-Feldman is not a doctrine of appellate finality; it is a rule about the allocation of judicial authority between state courts, federal district courts, and the United States Supreme Court. Once a state court has entered the judgment allegedly causing the plaintiff’s injury, review belongs in the state appellate system and, ultimately, in the Supreme Court—not in a federal district court. A pending state appeal does not create lower federal jurisdiction where Congress has withheld it.
For Florida practitioners, the decision aligns comfortably with the Eleventh Circuit’s modern treatment of the doctrine after Exxon Mobil Corp. v. Saudi Basic Industries Corp., 544 U.S. 280 (2005). In Nicholson v. Shafe, 558 F.3d 1266 (11th Cir. 2009), the Eleventh Circuit emphasized that Rooker-Feldman is a narrow jurisdictional doctrine, not a substitute for preclusion law. More recently, in Behr v. Campbell, 8 F.4th 1206 (11th Cir. 2021), the court criticized the tendency to invoke Rooker-Feldman whenever a federal action bore some relationship to earlier state litigation. Instead, the court required a claim-by-claim analysis focused on whether the plaintiff seeks relief from an injury caused by the state-court judgment itself.
T.M. reinforces that framework while resolving a separate temporal question the Eleventh Circuit had previously treated as significant: a litigant can no longer argue that Rooker-Feldman is categorically inapplicable merely because the underlying state judgment remains on appeal.
The decision may prove especially consequential in bankruptcy practice. A familiar scenario involves a debtor filing bankruptcy after entry of a foreclosure judgment, money judgment, or receivership order while a state appeal is still pending, then commencing an adversary proceeding alleging fraud, lack of standing, due process violations, or similar defects in the state proceeding. After T.M., the debtor cannot avoid Rooker-Feldman simply by arguing that the state judgment lacks appellate finality.
That does not mean every bankruptcy proceeding touching the same subject matter is barred. Bankruptcy courts remain fully authorized to adjudicate matters arising under the Bankruptcy Code, including stay violations, claims objections, discharge disputes, preferences, and fraudulent transfer actions created by federal bankruptcy law. The key distinction is between an impermissible de facto appeal of the state judgment and a genuinely independent federal claim. A debtor’s request to declare a foreclosure judgment void because it was procured by fraud is likely to trigger Rooker-Feldman; a trustee’s avoidance action under Section 548 does not, because it arises from statutory authority conferred by Congress rather than from appellate review of the state judgment.
The practical lesson is direct. Before invoking Rooker-Feldman—or resisting it—counsel should separate jurisdiction from preclusion and identify the source of the alleged injury. The relevant question is no longer whether the state appeal has ended. The question is whether the federal court is being asked, in substance, to review and reject a state-court judgment. If it is, T.M. confirms that neither the district court nor the bankruptcy court is the proper forum.
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