T.M., the petitioner in this case, has a rare condition that can cause temporary psychosis. After one such episode, she was involuntarily committed to a state hospital, which took steps to medicate her against her will. In a lawsuit to vindicate her rights in federal district court, T.M. alleged that she agreed to a consent decree in state court under duress to secure her release. She alleged that the state court consent order, which indefinitely dictated her treatment plan going forward, violated her constitutional rights. She argued that her lawsuit belonged in federal court because federal courts have jurisdiction in cases arising under federal law and, specifically, in lawsuits against state officials for civil rights violations.

The federal district court dismissed T.M.’s case, applying the Rooker-Feldman doctrine, which prohibits federal courts from adjudicating cases attempting to appeal a judgment of a state’s highest court. But T.M. was not seeking review of a judgment of a state’s highest court—at the time T.M. filed her lawsuit in federal court, she had also appealed the consent decree to a state appellate court, and that appeal remained pending.

The Fourth Circuit affirmed, and T.M. asked the Supreme Court to hear her case. In January 2026, CAC filed an amicus brief explaining why Rooker-Feldman does not bar T.M.’s search for justice in federal court.

Congress created federal question jurisdiction to empower federal courts to secure federal rights, like the constitutional rights T.M. is trying to vindicate. At the Founding, the Framers recognized that existing state court systems would not always be sufficient to protect federal interests. In subsequent decades, Congress expanded federal question jurisdiction, often reflecting Congress’s increasing frustration with brazen and unlawful conduct in the state courts. During Reconstruction, Congress passed a series of laws meant to protect and secure federal rights, in part through access to the federal courts. While opponents protested that these laws would let federal courts interfere with state judicial systems, supporters countered that this was precisely the point, due to widespread abuses by the state courts. By granting the federal courts civil rights jurisdiction in 1871 (in the same statute that created the cause of action for civil rights cases now known as § 1983) and federal question jurisdiction in 1875, Congress empowered lower federal courts to protect federal rights at a time when state courts could not be trusted to do so.

Ever since, litigants who want to vindicate their federal rights have often sought to do so in federal court. But in the twentieth century, in decisions separated by nearly sixty years, the Supreme Court dismissed two cases for lack of jurisdiction when state-court litigants, complaining of constitutional violations, sought review in federal district court of judgments of state courts of last resort. These cases created the “Rooker-Feldman doctrine.” Now, despite the Supreme Court’s subsequent admonishments that the Rooker-Feldman doctrine should be exceptionally narrow in scope, the lower federal courts sometimes apply it capaciously to dismiss cases brought in federal court.

The Supreme Court has never applied the Rooker-Feldman doctrine in a case like this one, where the state-court judgment is still subject to further review in the state court system. Rather, the Supreme Court’s precedents establish that the Rooker-Feldman doctrine only applies to final decisions of state courts of last resort, for which the exclusive avenue for review is to seek a Supreme Court writ of certiorari. Any expansion of the Rooker-Feldman doctrine beyond this narrow scope would be completely at odds with the history of Congress’s effort to throw open the doors of the lower federal courts for the vindication of federal rights.

Because there was no final judgment of a state court of last resort in T.M.’s case, Rooker-Feldman does not apply. The lower federal courts have jurisdiction to hear her case, just as the Reconstruction Congress that conferred that jurisdiction intended.