The justices on Monday considered the proper relationship between state and federal courts and wrestled with confusion surrounding a doctrine addressing that relationship as they heard oral argument in T.M. v. University of Maryland Medical System.
The dispute began approximately three years ago, when a Maryland woman, identified only as T.M., was involuntarily admitted to Baltimore Washington Medical Center after experiencing a psychotic episode. Over the next three months, T.M. and her family filed several state and federal lawsuits against the hospital, challenging doctors’ treatment plan and seeking to secure her release. Most relevant to the Supreme Court case is the petition she filed in Maryland state court in May 2023, in which she alleged that her involuntary commitment was unlawful.
While that petition was pending, T.M., her family, hospital staff, and attorneys negotiated a settlement agreement that outlined conditions under which T.M. could be released, including that she would continue taking medicine prescribed by the hospital and begin seeing a new psychiatrist. In June 2023, the state judge assigned to T.M.’s case entered this agreement as a consent order, and T.M. was released from the hospital.
Once home, T.M. filed a new federal lawsuit against Baltimore Washington Medical Center, the University of Maryland Medical System, and leaders of those institutions over the consent order, alleging that she had agreed to it under duress and that it “violates the Maryland Declaration of Rights and the Due Process clause of the Fourteenth Amendment and is therefore unconstitutional, unenforceable, and void.” T.M. also appealed the order to Maryland’s intermediate appellate court.
On Monday, the Supreme Court considered whether T.M.’s federal lawsuit can proceed or if – as a federal district court in Maryland and the U.S. Court of Appeals for the 4th Circuit held – lower federal courts do not have the authority to review it under a legal principle known as the Rooker-Feldman doctrine. That doctrine bars lower federal courts from hearing “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,” as Justice Ruth Bader Ginsburg summarized in a 2005 case called Exxon Mobil Corp. v. Saudi Basic Industries Corp.
The specific question before the justices on Monday was whether the Rooker-Feldman doctrine applies when the state-court judgment at issue – here, the consent order – remains subject to further review in state courts.
Lisa Blatt, who argued on behalf of the hospital and health system, asserted that a ruling for her clients would not undo the court’s effort to narrow the application of the Rooker-Feldman doctrine in Exxon. In Exxon, the court held that “Rooker-Feldman almost may never apply,” Blatt said, but that doesn’t mean it never applies, and “it happens to apply” to T.M.’s case.
Blatt emphasized that Congress explicitly said it “wanted no federal review of state court judgments until the state’s highest court has had the opportunity to correct any errors” in the federal statute that provides a basis for the Rooker-Feldman doctrine. She contended that allowing lower federal courts to review a judgment that’s still under review in the state courts would “damage[] the integrity of the state appellate process.”
Elizabeth Prelogar, who argued on behalf of T.M., offered a different take on that federal statute, which provides that “[f]inal judgments or decrees rendered by the highest court of a State in which a decision could be had, may be reviewed by the Supreme Court.” Prelogar contended that this addresses the Supreme Court’s ability to review state-court judgments, not the work of all federal courts. “Section 1257 says nothing at all about district court jurisdiction when there’s no final judgment of a state high court,” she said.
Although several justices noted that lower courts struggle to apply the Rooker-Feldman doctrine, they questioned whether embracing T.M.’s vision of the doctrine would actually do anything to clear things up. For example, Justice Samuel Alito said that he doesn’t “really see a rational basis for drawing a distinction between a case where the state court proceeding has concluded and a case where the state court proceeding is ongoing.” And Justice Elena Kagan observed that “[t]here are a lot of things that have confounded the lower courts on Rooker-Feldman, but I’m not sure that this question necessarily is one of them.”
Justices Sonia Sotomayor and Brett Kavanaugh pressed Prelogar on the “value,” as Sotomayor put it, of “having a federal district court and a state appellate court simultaneously reviewing a state court judgment.” Prelogar responded that “there is a significant value in ensuring that federal courts are available to vindicate federal rights, including when state court judgments themselves give rise to that kind of constitutional violation.”
Whether to overrule the Rooker-Feldman doctrine altogether was not a question presented in the case, but multiple justices nonetheless brought up that possibility during Monday’s debate. Prelogar emphasized that the court does not need to overrule the doctrine in order to side with T.M., but she also described it as “egregiously wrong” and “out of sync with modern precedent about how the Court articulates jurisdictional rules.” She noted that overruling Roe v. Wade was not a question presented in Dobbs v. Jackson Women’s Health Organization, the 2022 case in which the court overturned the constitutional right to abortion. “So the Court has sometimes, when it’s delved into a doctrine, decided that it makes sense to reconsider precedent,” Prelogar said.
For her part, Blatt asserted that “[t]his is not Dobbs” and “[t]his is not Roe v. Wade,” and she urged the court not to overrule the Rooker-Feldman doctrine. Indeed, Blatt went so far as to proclaim that the justices are “not going to overrule Rooker” but then apologized and adjusted her statement to “I don’t think you’re doing to do that” “in an April case.” Several of those present at the argument laughed long and hard at Blatt’s comments before Alito responded, “Don’t dare my colleagues.”
The court’s ruling is expected by early July.
The post Justices debate the relationship between state and federal courts appeared first on SCOTUSblog.