Access to Justice

CAC Release: Court Further Muddies the Waters on the Scope of the Rooker-Feldman Doctrine in Majority Opinion that Ignores Critical Reconstruction-Era History Regarding the Role of Federal Courts as the Chief Guardians of Federal Rights

WASHINGTON, DC – Following today’s decision at the Supreme Court in T.M. v. University of Maryland Medical System, a case in which the Court considered whether the Rooker-Feldman doctrine requires dismissal of a request for relief from a state-court decision that did not reach the state’s highest court, Constitutional Accountability Center Senior Appellate Counsel Miriam Becker-Cohen issued the following reaction:

In today’s disappointing decision, the Court pushed the Rooker-Feldman doctrine even further away from its only arguable textual underpinnings in 28 U.S.C. § 1257, a statute that vests the Supreme Court with exclusive jurisdiction to review final judgments of a state’s highest court. In this case, the challenged state-court order remains subject to further appellate review within the state-court system, yet the majority nonetheless used that doctrine to affirm dismissal of T.M.’s federal civil rights case.

This was wrong for a variety of reasons, as Justice Barrett laid out in her compelling dissent. Drawing directly on important excerpts from a prior Supreme Court opinion cited and discussed exclusively in our amicus brief, Justice Barrett also emphasized that the majority’s opinion “sits uneasily with the fact that T.M.’s suit arises under 42 U.S.C. § 1983,” a statute enacted to “interpose the federal courts between the States and the people, as guardians of the people’s federal rights.”

Yet as Justice Barrett noted, “the news is not all bad.” Even though the Court’s majority further muddied the waters regarding the scope of Rooker-Feldman and undid prior efforts by the Court to provide clarity, it also repeatedly emphasized the narrowness of the doctrine. For lower courts, that point should be the chief takeaway from the majority’s opinion.

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