T.M. v. University of Maryland Medical System
No. 25-197 · October Term 2025 · Judicial Power · decided June 18, 2026
Decided: University of Maryland Medical System won 5-4. The model was wrong.
Expected vote 6–3 for T.M.. Chance of a unanimous ruling 45%. FantasySCOTUS crowd: 65% T.M..
The case
T.M., a woman involuntarily committed, is suing the University of Maryland Medical System, alleging that a state court consent order she signed to secure her release was unconstitutional and entered under duress. The lower courts dismissed her federal lawsuit, citing the Rooker-Feldman doctrine, which generally prevents federal courts from reviewing state court judgments. The Supreme Court must now decide whether the Rooker-Feldman doctrine applies even when the state court judgment in question is still subject to further review within the state court system.
- Does the Rooker-Feldman doctrine apply to state court judgments that are not yet final under state law, or only to those that have exhausted all state-level appeals?
- What constitutes a 'state-court loser' for the purposes of the Rooker-Feldman doctrine, especially when a party has entered into a consent order?
- How does the principle of federalism, which limits federal court interference in state matters, balance against the right to challenge constitutional violations in federal court?
- What are the implications for individuals who claim to have entered into state court agreements under duress, if federal courts are barred from reviewing such claims?
AI brief written by gemini-2.5-flash from the questions presented and the Oyez facts on 2026-10-02. Commentary only; it is not an input to the model.
Question presented, as filed
Whether the Rooker-Feldman doctrine can be triggered by a state-court decision that remains subject to further review in state court.
Facts of the case (Oyez)
In March 2023, T.M., a woman with a rare medical condition that triggers psychosis upon consuming gluten, was involuntarily committed to Baltimore Washington Medical Center after an episode. Her treating psychiatrist sought and received state approval to forcibly administer antipsychotic medication; T.M. contested this but was unsuccessful in administrative proceedings. Independent psychiatrists later stated that T.M. no longer required inpatient care. To secure her release, T.M. and the hospital negotiated an oral agreement, which was formalized as a state court consent order. The order allowed her to leave the hospital on the condition that she comply with ongoing psychiatric treatment and medications, switch providers, and drop pending lawsuits. Her parents, J.M. and A.M., were also bound to notify authorities if she failed to comply. Ten days later, represented by new counsel, T.M. and her parents filed the present federal lawsuit claiming that the consent order was unconstitutional and entered under duress. They challenged the order as violating T.M.’s due process rights and sought declaratory and injunctive relief invalidating its enforcement. They did not request damages or challenge the initial commitment decisions. The U.S. District Court for the District of Maryland dismissed the lawsuit. It held that T.M.’s claims were barred by the Rooker-Feldman doctrine, which prevents parties who lose in state courts from challenging injuries caused by state-court judgments, because they amounted to a request for federal review of a state court judgment. It also dismissed the parents’ claims for failure to state a constitutional violation. The U.S. Court of Appeals for the Fourth Circuit affirmed, concluding that T.M. was a “state-court loser” seeking to undo a state judgment still reviewable in Maryland courts. Nonetheless, it remanded for the district court to modify T.M.’s dismissal to be without prejudice, due to lack of jurisdiction.
The nine
Each justice's predicted vote and the record behind it: how often they have voted for the petitioner overall, in Judicial Power cases, and when the lower court ruled conservative; and, once argued, how many questions they put to each side (the side a justice questions more tends to lose their vote). The note under each row is the AI brief's reading, commentary rather than model input.
| Justice | Predicted | Overall | This issue | Lower court conservative | At argument | Voted |
|---|---|---|---|---|---|---|
John G. Roberts Republican appointee · since OT2005 Chief Justice Roberts often emphasizes judicial restraint and the proper scope of federal court jurisdiction, which could lead him to carefully consider the limits of the Rooker-Feldman doctrine. His jurisprudence frequently seeks to maintain a clear division between state and federal judicial authority. | 59% T.M. | 68% for the petitioner · 1,512 votes | 69% Judicial Power · 197 votes | 61% lower court conservative · 734 votes | 9 / 3 questions at T.M. / University | T.M. ✓ |
Clarence Thomas Republican appointee · since OT1991 Justice Thomas is a strong proponent of originalism and textualism, and he often scrutinizes the historical basis and precise wording of jurisdictional doctrines. He may consider whether the Rooker-Feldman doctrine, as applied here, aligns with the original understanding of federal court power. | 59% T.M. | 59% for the petitioner · 2,801 votes | 57% Judicial Power · 388 votes | 43% lower court conservative · 1,365 votes | 4 / 2 questions at T.M. / University | University of Maryland Medical System ✗ |
Samuel A. Alito Republican appointee · since OT2005 Justice Alito typically favors a strict interpretation of jurisdictional rules and has often sided with limiting federal court intervention in state affairs. His focus on established procedural bars could influence his view on whether the Rooker-Feldman doctrine should be broadly applied. | 64% T.M. | 62% for the petitioner · 1,469 votes | 65% Judicial Power · 190 votes | 48% lower court conservative · 722 votes | 5 / 2 questions at T.M. / University | University of Maryland Medical System ✗ |
Sonia Sotomayor Democratic appointee · since OT2009 Justice Sotomayor often considers the practical impact of legal doctrines on individuals, particularly those who may be vulnerable or lack full legal representation. Her analysis might focus on whether applying Rooker-Feldman in this context would unduly restrict access to federal courts for constitutional claims. | 66% T.M. | 61% for the petitioner · 1,192 votes | 58% Judicial Power · 149 votes | 76% lower court conservative · 594 votes | 12 / 4 questions at T.M. / University | University of Maryland Medical System ✗ |
Elena Kagan Democratic appointee · since OT2010 Justice Kagan often seeks to balance competing legal principles and may look for a pragmatic interpretation of the Rooker-Feldman doctrine that avoids both overreach and under-enforcement. She might explore the nuances of what constitutes a 'final' state court judgment for jurisdictional purposes. | 66% T.M. | 63% for the petitioner · 1,072 votes | 61% Judicial Power · 137 votes | 75% lower court conservative · 543 votes | 6 / 9 questions at T.M. / University | T.M. ✓ |
Neil M. Gorsuch Republican appointee · since OT2016 Justice Gorsuch often emphasizes the importance of clear jurisdictional lines and has expressed skepticism about judge-made doctrines that expand federal power. He may scrutinize the origins and scope of the Rooker-Feldman doctrine to ensure it is applied consistently with constitutional and statutory limits. | 66% T.M. | 65% for the petitioner · 592 votes | 69% Judicial Power · 83 votes | 59% lower court conservative · 286 votes | 14 / 1 questions at T.M. / University | T.M. ✓ |
Brett M. Kavanaugh Republican appointee · since OT2018 Justice Kavanaugh often takes a pragmatic approach to jurisdictional questions, seeking to provide clear guidance for lower courts. He might consider how a ruling in this case would affect the efficiency and predictability of federal court litigation involving state court judgments. | 66% T.M. | 69% for the petitioner · 498 votes | 73% Judicial Power · 62 votes | 62% lower court conservative · 244 votes | 4 / 0 questions at T.M. / University | University of Maryland Medical System ✗ |
Amy Coney Barrett Republican appointee · since OT2020 Justice Barrett often focuses on textual fidelity and the plain meaning of statutes and rules. Her analysis of the Rooker-Feldman doctrine would likely center on its precise formulation and whether the facts of this case fall squarely within its established parameters. | 66% T.M. | 66% for the petitioner · 360 votes | 71% Judicial Power · 49 votes | 60% lower court conservative · 178 votes | 8 / 0 questions at T.M. / University | T.M. ✓ |
Ketanji Brown Jackson Democratic appointee · since OT2022 Justice Jackson often brings a perspective that considers the real-world implications of legal doctrines, particularly for individuals navigating complex legal systems. She may examine whether the application of Rooker-Feldman here would create an unfair barrier for individuals seeking to challenge state court orders based on constitutional grounds. | 66% T.M. | 59% for the petitioner · 244 votes | 60% Judicial Power · 37 votes | 80% lower court conservative · 127 votes | 15 / 5 questions at T.M. / University | University of Maryland Medical System ✗ |
Rates are each justice's own participation record in the Supreme Court Database, the same history the model trains on; a rate on fewer than five votes is not shown. The predicted vote is VotePredictor SCOTUS' per-justice probability from the served model, which also reads the bench-wide transcript signal and how long each side held the podium.
Every call this term, justice by justice · how the model is built and its record. Data as of 2026-10-02.