Gordon Rees Scully Mansukhani, LLP
MONTH-IN-BRIEF (Aug 2026)
The following pieces are part of a series of summaries of the leading cases related to bankruptcy decided in the last two years.
Rooker-Feldman Doctrine: T. M. v. University of Maryland Medical System Corp., 146 S. Ct. 1739 (2026)
By Mingxian (Felix) Bao, Columbia Law School
The Rooker-Feldman doctrine bars federal suits seeking review and rejection of state court judgments. The doctrine derives from a pair of cases. Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923), held that a federal district court could not declare a state court judgment null and void under the U.S. Constitution because doing so required an exercise of appellate jurisdiction over state courts, a power belonging only to the Supreme Court. District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (1983), held that a federal district court lacked jurisdiction to review a final judgment issued by a state high court because such review could only be obtained in the Supreme Court. Ambiguity remained as to whether the doctrine applied only to final judgments rendered by the highest court of a state—in other words, after the plaintiff had exhausted all avenues of appeal in state court—or to final judgments issued by any state court, including those judgments by a state trial court pending appeal in state appellate courts. In T. M. v. University of Maryland Medical System Corp., 146 S. Ct. 1739 (2026), the Supreme Court eliminated this ambiguity by holding that the Rooker-Feldman doctrine would prevent federal district courts from reviewing a final judgment issued by state courts, regardless of whether such judgment is issued by the highest court of a state.
