T.M. v. University of Maryland Medical System Corp.
Decision
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TikTok Opinion of the Court
Overview
Overview
A case in which the Court will decide whether the Rooker-Feldman doctrine can be triggered by a state-court decision that remains subject to further review in state court.
The Facts
Facts
T.M., a patient with a medical condition causing altered mental states from gluten exposure, was involuntarily committed to University of Maryland Medical System and a psychiatrist attempted to administer a forced medication injection. T.M. challenged the involuntary commitment and forced medication in federal court, but courts ruled the Rooker-Feldman doctrine barred federal review because state courts had already ruled on the matter.
The Issue
Issue
Whether a private hospital's involuntary psychiatric commitment and attempted forced medication of a patient with a documented metabolic disorder violates federal constitutional or statutory rights, and what process is constitutionally required before a private medical facility may administer involuntary psychotropic medication.
The Rules
Rule
Under Washington v. Harper, 494 U.S. 210 (1990), involuntary administration of antipsychotic drugs implicates a constitutionally protected liberty interest. Bodily integrity is a fundamental liberty interest under the substantive due process doctrine. Section 504 of the Rehabilitation Act and the ADA prohibit discrimination against individuals with disabilities by entities receiving federal funding, including private hospitals.
The Application
Analysis
T.M. Argues the Rooker-Feldman doctrine does not bar federal jurisdiction when underlying state court proceedings are not yet final. Her federal civil rights claims arise independently from the involuntary commitment and forced medication. They are original claims challenging state actors' conduct, not disguised appeals from a state court judgment.
The Conclusion
Conclusion
The Rooker-Feldman doctrine does not bar T.M.'s federal claims. The question is whether the federal plaintiff is complaining of injuries caused by a state-court judgment. Not whether the claims are "inextricably intertwined" with state proceedings. Affirmed.
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