Pro Bono Client Wins Supreme Court Review of Rooker-Feldman Doctrine

Paul, Weiss won U.S. Supreme Court review of a Fourth Circuit decision involving federal court jurisdiction over a state court judgment under the Rooker-Feldman doctrine. The Court will consider whether this jurisdictional doctrine can be triggered by a state court decision that remains subject to further review in state court.

Our client, known as T.M., has a rare medical condition in which ingesting any amount of gluten can cause changes to her mental status, including by inducing psychosis. In 2023, she experienced a psychotic episode after ingesting gluten and was admitted involuntarily to Baltimore Washington Medical Center, where she was confined against her will for three months. In response to T.M.’s treatment at the medical center, our client and her father filed a series of legal actions in Maryland state court to obtain relief during her involuntary commitment, and in Maryland federal court alleging that the medical center and others had violated her federal and state constitutional rights. The medical center then agreed to release our client if she signed a consent order requiring certain post-release conditions, including the dismissal of all legal actions. Fearing that she would continue to be forcibly medicated by the center, she signed the agreement to secure her release.

Ten days after the consent order was entered in Maryland state court, our client and her parents filed this action in federal district court against the University of Maryland Medical System Corporation, the medical center and certain individuals, seeking a declaration that the consent order violated T.M’s federal and state constitutional rights; a declaration that the order was obtained under duress; and injunctive relief preventing enforcement of the order. Days later, she also appealed the consent order to the Appellate Court of Maryland. The state appellate court stayed proceedings pending the outcome of the federal litigation.

Despite the pending state court proceedings, the federal court dismissed the case of its own accord under the Rooker-Feldman doctrine. The doctrine, which has led to a circuit split among 10 different circuit courts, says that a federal district court lacks jurisdiction to entertain a claim filed by a party who lost in state court and is asking the federal court to invalidate a final state-court judgment. The Fourth Circuit affirmed, reasoning that, for the purposes of Rooker-Feldman, the consent order constituted an adverse state court judgment against T.M. The Fourth Circuit held that the state court’s judgment was final because the state court’s stay of proceedings meant that our client was effectively asking the Fourth Circuit to entertain an appeal of a state court judgment that was “presently insulated” from all further state court review. The Fourth Circuit rejected T.M.’s argument that the Rooker-Feldman doctrine is inapplicable where further review of the state court judgment in question is still available.

Brought on for the Supreme Court appeal, Paul, Weiss argued in its petition for review that the Fourth Circuit incorrectly sided with the minority view among the circuit courts, and that there is no valid legal basis or practical reasoning for applying Rooker-Feldman to state court judgments that remain subject to further review in state court, among other arguments.

The Paul, Weiss team includes litigation partners Kannon Shanmugam, Masha Hansford and William Marks and associates Mikaela Milligan, Anna Lucardi and Matthew Disler.