Opinion Summary: T.M. v. UMD MSC | Rooker-Feldman Bars T.M.'s Lawsuit

Oral Argument Re-Listen: T.M. v. UMD MSC | Does Rooker-Feldman Bar T.M.'s Lawsuit?

T.M. v. University of Maryland Medical System Corporation | Case No. 25-197 | Docket Link: Here [https://www.supremecourt.gov/search.aspx?filename=/docket/docketfiles/html/public/25-197.html] | Argued: April 20, 2026 | Decided: June 18, 2026 Overview: A Maryland woman signed a state-court consent order to secure release from involuntary psychiatric commitment, then challenged that order in federal district court while her state-court appeal remained pending — pushing the limits of the Rooker-Feldman doctrine. Question Presented: Whether the Rooker-Feldman doctrine bars federal district court jurisdiction over suits challenging state-court judgments that remain subject to further review in state appellate proceedings. Posture: Fourth Circuit affirmed District Court's dismissal of T.M.'s complaint under Rooker-Feldman for lack of jurisdiction. Main Arguments: T.M. (Petitioner): * (1) Rooker-Feldman applies only after state proceedings end, per Exxon Mobil's confinement to the procedural circumstances of Rooker and Feldman; * (2) Section 1257 cannot support a negative inference extending the doctrine to non-final state-court judgments; * (3) preclusion and abstention doctrines adequately address federalism concerns without imposing a blunt jurisdictional bar. UMD Medical System (Respondent): * (1) Exxon Mobil's four-element test contains no finality requirement; district courts lack appellate jurisdiction to void state-court judgments regardless of pending state review; * (2) T.M. satisfies every Rooker-Feldman element — she asked a federal court to declare void a consent order entered ten days before she filed; * (3) T.M.'s rule spawns parallel duplicative litigation, gamesmanship, and federalism harm that abstention and preclusion fail to prevent. Holding: The Rooker-Feldman doctrine bars federal district court jurisdiction over suits brought by state-court losers complaining of injuries caused by state-court judgments rendered before the district court proceedings commenced and seeking federal review and rejection of those judgments, regardless of whether the state-court judgment remains subject to further review in state appellate proceedings. Affirmed. Voting Breakdown: 5-4. Justice Sotomayor delivered the opinion of the Court, joined by Justices Thomas, Alito, Kavanaugh, and Jackson. Justice Thomas filed a concurring opinion. Justice Barrett filed a dissenting opinion, joined by Chief Justice Roberts and Justices Kagan and Gorsuch. Fourth Circuit affirmed. Opinion: Here [https://www.supremecourt.gov/opinions/25pdf/25-197_bp7c.pdf] Majority Reasoning: * (1) T.M.'s finality theory contradicts precedent — Rooker (1923), Feldman (1983), and Exxon Mobil (2005) all rest on a functional distinction between original and appellate jurisdiction, not on section 1257's finality requirement; * (2) T.M.'s rule produces arbitrary results and invites gamesmanship — identical plaintiffs with different filing timing reach opposite outcomes; * (3) abstention and preclusion doctrines don't substitute where a plaintiff directly attacks a state-court judgment as the source of injury. Separate Opinions: * Justice Thomas concurred in full, writing separately to ground Rooker in constitutional text and Founding history — the power to revise another court's judgment always constituted appellate jurisdiction, and Congress never granted district courts that revising power over state civil judgments. * Justice Barrett dissented, joined by Chief Justice Roberts and Justices Kagan and Gorsuch. The dissent argued Exxon Mobil confined the doctrine to cases filed "after the state proceedings ended," and the majority expanded a doctrinally shaky rule beyond Exxon's mandate. Implications: * (1) State-court losers cannot access federal district court while state appeals remain open — they must exhaust state remedies first; * (2) The core Rooker-Feldman ambiguity — distinguishing judgment attacks from independent federal claims — survives and drives future litigation; * (3) T.M. retains a stayed Maryland state appeal and may yet petition the Supreme Court if constitutional questions survive. The Fine Print: * 28 U.S.C. § 1257(a): "Final judgments or decrees rendered by the highest court of a State in which a decision could be had, may be reviewed by the Supreme Court by writ of certiorari where the validity of a treaty or statute of the United States is drawn in question..." * 28 U.S.C. § 1331: "The district courts shall have original jurisdiction of all civil actions arising under the Constitution, laws, or treaties of the United States." Primary Cases: * Exxon Mobil Corp. v. Saudi Basic Industries Corp. (2005): Rooker-Feldman doctrine "confined to cases brought by state-court losers complaining of injuries caused by state-court judgments rendered before the district court proceedings commenced and inviting district court review and rejection of those judgments" — the central precedent both sides claimed as support. * Rooker v. Fidelity Trust Co. (1923): Federal district courts lack jurisdiction to reverse or modify state-court judgments — such relief constitutes an exercise of appellate jurisdiction that Congress vested exclusively in the Supreme Court. Timestamps: [00:00:00] Argument Preview [00:01:15] Oral Advocates [00:01:27] Argument Begins [00:01:35] T.M. Opening Statement [00:03:51] T.M. Free for All Questions [00:27:56] T.M. Round Robin Questions [00:42:13] UMD Medical Opening Statement [00:44:01] UMD Medical Free for All Questions [00:59:41] UMD Medical Round Robin Questions [00:59:50] T.M. Rebuttal

Opinion Summary: T.M. v. UMD MSC | Rooker-Feldman Bars T.M.'s Lawsuit

T.M. v. University of Maryland Medical System Corporation | Case No. 25-197 | Docket Link: Here [https://www.supremecourt.gov/search.aspx?filename=/docket/docketfiles/html/public/25-197.html] | Argued: April 20, 2026 | Decided: June 18, 2026 Overview: A Maryland woman signed a state-court consent order to secure release from involuntary psychiatric commitment, then challenged that order in federal district court while her state-court appeal remained pending — pushing the limits of the Rooker-Feldman doctrine. Question Presented: Whether the Rooker-Feldman doctrine bars federal district court jurisdiction over suits challenging state-court judgments that remain subject to further review in state appellate proceedings. Posture: Fourth Circuit affirmed District Court's dismissal of T.M.'s complaint under Rooker-Feldman for lack of jurisdiction. Main Arguments: T.M. (Petitioner): * (1) Rooker-Feldman applies only after state proceedings end, per Exxon Mobil's confinement to the procedural circumstances of Rooker and Feldman; * (2) Section 1257 cannot support a negative inference extending the doctrine to non-final state-court judgments; * (3) preclusion and abstention doctrines adequately address federalism concerns without imposing a blunt jurisdictional bar. UMD Medical System (Respondent): * (1) Exxon Mobil's four-element test contains no finality requirement; district courts lack appellate jurisdiction to void state-court judgments regardless of pending state review; * (2) T.M. satisfies every Rooker-Feldman element — she asked a federal court to declare void a consent order entered ten days before she filed; * (3) T.M.'s rule spawns parallel duplicative litigation, gamesmanship, and federalism harm that abstention and preclusion fail to prevent. Holding: The Rooker-Feldman doctrine bars federal district court jurisdiction over suits brought by state-court losers complaining of injuries caused by state-court judgments rendered before the district court proceedings commenced and seeking federal review and rejection of those judgments, regardless of whether the state-court judgment remains subject to further review in state appellate proceedings. Affirmed. Voting Breakdown: 5-4. Justice Sotomayor delivered the opinion of the Court, joined by Justices Thomas, Alito, Kavanaugh, and Jackson. Justice Thomas filed a concurring opinion. Justice Barrett filed a dissenting opinion, joined by Chief Justice Roberts and Justices Kagan and Gorsuch. Fourth Circuit affirmed. Opinion: Here [https://www.supremecourt.gov/opinions/25pdf/25-197_bp7c.pdf] Majority Reasoning: * (1) T.M.'s finality theory contradicts precedent — Rooker (1923), Feldman (1983), and Exxon Mobil (2005) all rest on a functional distinction between original and appellate jurisdiction, not on section 1257's finality requirement; * (2) T.M.'s rule produces arbitrary results and invites gamesmanship — identical plaintiffs with different filing timing reach opposite outcomes; * (3) abstention and preclusion doctrines don't substitute where a plaintiff directly attacks a state-court judgment as the source of injury. Separate Opinions: * Justice Thomas concurred in full, writing separately to ground Rooker in constitutional text and Founding history — the power to revise another court's judgment always constituted appellate jurisdiction, and Congress never granted district courts that revising power over state civil judgments. * Justice Barrett dissented, joined by Chief Justice Roberts and Justices Kagan and Gorsuch. The dissent argued Exxon Mobil confined the doctrine to cases filed "after the state proceedings ended," and the majority expanded a doctrinally shaky rule beyond Exxon's mandate. Implications: * (1) State-court losers cannot access federal district court while state appeals remain open — they must exhaust state remedies first; * (2) The core Rooker-Feldman ambiguity — distinguishing judgment attacks from independent federal claims — survives and drives future litigation; * (3) T.M. retains a stayed Maryland state appeal and may yet petition the Supreme Court if constitutional questions survive. The Fine Print: * 28 U.S.C. § 1257(a): "Final judgments or decrees rendered by the highest court of a State in which a decision could be had, may be reviewed by the Supreme Court by writ of certiorari where the validity of a treaty or statute of the United States is drawn in question..." * 28 U.S.C. § 1331: "The district courts shall have original jurisdiction of all civil actions arising under the Constitution, laws, or treaties of the United States." Primary Cases: * Exxon Mobil Corp. v. Saudi Basic Industries Corp. (2005): Rooker-Feldman doctrine "confined to cases brought by state-court losers complaining of injuries caused by state-court judgments rendered before the district court proceedings commenced and inviting district court review and rejection of those judgments" — the central precedent both sides claimed as support. * Rooker v. Fidelity Trust Co. (1923): Federal district courts lack jurisdiction to reverse or modify state-court judgments — such relief constitutes an exercise of appellate jurisdiction that Congress vested exclusively in the Supreme Court. Oral Advocates: * Petitioner (T.M.): Elizabeth B. Prelogar of Cooley LLP * Respondents (University of Maryland Medical System Corporation): Lisa S. Blatt of Williams & Connolly LLP

Oral Argument Re-Listen: Abouammo v. United States | Trial on Home Turf Not Government's Pick

FS Credit Opportunities Corp. v. Saba Capital Master Fund, Ltd. | Case No. 24-345 | Docket Link: Here [https://www.supremecourt.gov/docket/docketfiles/html/public/24-345.html] | Argued: 12/10/2025 | Decided: 06/11/2026 Overview: The Investment Company Act case addresses whether Section 47(b) grants private parties the right to sue for contract rescission, testing the limits of implied private rights of ac Oral Advocates: * Petitioner (Abouammo): Tobias Loss-Eaton of Sidley Austin * Respondent (United States): Anthony A. Yang, Assistant to the Solicitor General, Department of Justice. Question Presented: Whether Section 47(b) of the Investment Company Act impliedly empowers private parties to sue for contract rescission. Posture: District Court granted Saba summary judgment; Second Circuit summarily affirmed; Supreme Court reversed. Main Arguments: * Petitioner (the Funds): * (1) Section 47(b) directs courts on remedy application, not individuals on rights to sue — it lacks rights-creating language aimed at a particular class under Sandoval; * (2) The ICA's comprehensive SEC enforcement scheme and two express private rights of action elsewhere in the statute foreclose implied private enforcement; * (3) Congress's 1980 deletion of "shall be void" — the precise textual basis TAMA relied on — signals changed meaning and eliminates the implied right. * Respondent (Saba): * (1) Congress inserted "rescission" and "any party" into Section 47(b) in 1980, language presupposing an affirmative private right for both contract parties; * (2) TAMA's unanimous rescission holding survives the 1980 amendments, which refined rather than eliminated the private right; * (3) House and Senate Committee Reports expressly called for courts to imply private rights of action under the amended ICA. Holding: Section 47(b) of the ICA does not impliedly empower private parties to sue for rescission of contracts that allegedly violate the Act. Voting Breakdown: 6-3. Justice Barrett wrote the majority opinion joined by Chief Justice Roberts and Justices Thomas, Alito, Gorsuch, and Kavanaugh. Justice Kagan filed a dissenting opinion. Justice Jackson filed a dissenting opinion joined by Justice Sotomayor, with Justice Kagan joining Parts I and II. Reversed and remanded. Opinion: Here [https://www.supremecourt.gov/opinions/25pdf/25-5146_e29f.pdf] Majority Reasoning: * (1) Section 47(b)'s "a court may not deny rescission" language directs courts on remedy — it lacks rights-creating language aimed at a particular class of persons under Sandoval; * (2) The ICA's comprehensive SEC enforcement scheme and two express private rights of action elsewhere in the statute foreclose implied private enforcement; * (3) Congress's 1980 deletion of "shall be void" — the TAMA linchpin — signals changed meaning and removes the textual foundation for a private right. Separate Opinions: * Justice Kagan (dissenting alone): Agrees with Jackson's text-and-structure analysis that Section 47(b) supports a private right; declines to rely on legislative history, finding the provision not sufficiently ambiguous to require resort to committee reports. * Justice Jackson (dissenting, joined by Justice Sotomayor; Justice Kagan joins Parts I and II): Congress inserted "rescission" and "any party" into the 1980 amendments to preserve TAMA's rescission right; post-performance context makes affirmative suit the only practical remedy; Committee Reports expressly called for continued implied rights under the amended ICA. Implications: * (1) Activist investors lose the federal right to challenge closed-end fund governance under Section 47(b); the SEC remains the exclusive enforcer; * (2) Closed-end funds gain protection from private ICA rescission suits; state control-share adoption receives implicit judicial validation; * (3) The Court extends textualist limits on implied private rights of action, tightening Sandoval's framework further into securities law. The Fine Print: * Section 47(b)(2), 15 U.S.C. §80a-46(b)(2): "a court may not deny rescission at the instance of any party unless such court finds that under the circumstances the denial of rescission would produce a more equitable result than its grant and would not be inconsistent with the purposes of this subchapter." * Section 18(i), 15 U.S.C. §80a-18(i): "every share of stock hereafter issued by a registered management company . . . shall be a voting stock and have equal voting rights with every other outstanding voting stock." Primary Cases: * Alexander v. Sandoval (2001): Courts infer implied private rights of action only where a statute uses rights-creating language aimed at a particular class of persons; language directing courts or agencies falls short. * Transamerica Mortgage Advisors, Inc. v. Lewis (1979): The Investment Advisers Act's "shall be void" language created an implied private right of action for rescission; all nine justices agreed on that point. Timestamps: [00:00:00] Argument Preview [00:01:12] Argument Begins [00:01:21] Abouammo Opening Statement [00:03:30] Abouammo Free for All Questions [00:26:27] Abouammo Round Robin Questions [00:33:40] United States Opening Statement [00:35:54] United States Free for All Questions [01:04:34] United States Round Robin Questions [01:13:58] Abouammo Rebuttal

Oral Argument Re-Listen: FS Credit v. Saba | Fund Wins Fiduciary Fairness Fight

FS Credit Opportunities Corp. v. Saba Capital Master Fund, Ltd. | Case No. 24-345 | Docket: Here [https://www.supremecourt.gov/docket/docketfiles/html/public/24-345.html ] | Argued: 12/10/2025 | Decided: 06/11/2026 Overview: The Investment Company Act case addresses whether Section 47(b) grants private parties the right to sue for contract rescission, testing the limits of implied private rights of action against a comprehensive SEC enforcement scheme. Oral Advocates: * For Petitioner (FS Credit) and Respondents (BlackRock): Shay Dvoretzky, Washington, D.C. * For United States as Amicus Curiae in Support of FS Credit and BlackRock: Max E. Schulman, Assistant to the Solicitor General, Department of Justice * For Respondent (Saba): Paul D. Clement, Alexandria, VA Question Presented: Whether Section 47(b) of the Investment Company Act impliedly empowers private parties to sue for contract rescission. Posture: District Court granted Saba summary judgment; Second Circuit summarily affirmed; Supreme Court reversed. Main Arguments: * Petitioner (the Funds): * (1) Section 47(b) directs courts on remedy application, not individuals on rights to sue — it lacks rights-creating language aimed at a particular class under Sandoval; * (2) The ICA's comprehensive SEC enforcement scheme and two express private rights of action elsewhere in the statute foreclose implied private enforcement; * (3) Congress's 1980 deletion of "shall be void" — the precise textual basis TAMA relied on — signals changed meaning and eliminates the implied right. * Respondent (Saba): * (1) Congress inserted "rescission" and "any party" into Section 47(b) in 1980, language presupposing an affirmative private right for both contract parties; * (2) TAMA's unanimous rescission holding survives the 1980 amendments, which refined rather than eliminated the private right; * (3) House and Senate Committee Reports expressly called for courts to imply private rights of action under the amended ICA. Holding: Section 47(b) of the ICA does not impliedly empower private parties to sue for rescission of contracts that allegedly violate the Act. Voting Breakdown: 6-3. Justice Barrett wrote the majority opinion joined by Chief Justice Roberts and Justices Thomas, Alito, Gorsuch, and Kavanaugh. Justice Kagan filed a dissenting opinion. Justice Jackson filed a dissenting opinion joined by Justice Sotomayor, with Justice Kagan joining Parts I and II. Reversed and remanded. Opinion: Here [https://www.supremecourt.gov/opinions/25pdf/24-345_i42k.pdf] Majority Reasoning: * (1) Section 47(b)'s "a court may not deny rescission" language directs courts on remedy — it lacks rights-creating language aimed at a particular class of persons under Sandoval; * (2) The ICA's comprehensive SEC enforcement scheme and two express private rights of action elsewhere in the statute foreclose implied private enforcement; * (3) Congress's 1980 deletion of "shall be void" — the TAMA linchpin — signals changed meaning and removes the textual foundation for a private right. Separate Opinions: * Justice Kagan (dissenting alone): Agrees with Jackson's text-and-structure analysis that Section 47(b) supports a private right; declines to rely on legislative history, finding the provision not sufficiently ambiguous to require resort to committee reports. * Justice Jackson (dissenting, joined by Justice Sotomayor; Justice Kagan joins Parts I and II): Congress inserted "rescission" and "any party" into the 1980 amendments to preserve TAMA's rescission right; post-performance context makes affirmative suit the only practical remedy; Committee Reports expressly called for continued implied rights under the amended ICA. Implications: * (1) Activist investors lose the federal right to challenge closed-end fund governance under Section 47(b); the SEC remains the exclusive enforcer; * (2) Closed-end funds gain protection from private ICA rescission suits; state control-share adoption receives implicit judicial validation; * (3) The Court extends textualist limits on implied private rights of action, tightening Sandoval's framework further into securities law. The Fine Print: * Section 47(b)(2), 15 U.S.C. §80a-46(b)(2): "a court may not deny rescission at the instance of any party unless such court finds that under the circumstances the denial of rescission would produce a more equitable result than its grant and would not be inconsistent with the purposes of this subchapter." * Section 18(i), 15 U.S.C. §80a-18(i): "every share of stock hereafter issued by a registered management company . . . shall be a voting stock and have equal voting rights with every other outstanding voting stock." Primary Cases: * Alexander v. Sandoval (2001): Courts infer implied private rights of action only where a statute uses rights-creating language aimed at a particular class of persons; language directing courts or agencies falls short. * Transamerica Mortgage Advisors, Inc. v. Lewis (1979): The Investment Advisers Act's "shall be void" language created an implied private right of action for rescission; all nine justices agreed on that point. Timestamps: [00:00:00] Oral Argument Preview [00:01:23] Oral Argument Begins [00:01:36] Petitioner Opening Statement [00:03:40] Petitioner Free for All Questions [00:19:29] Petitioner Round Robin Questions [00:30:53] United States as Amicus Curiae Opening Statement [00:32:17] United States Free for All Questions [00:42:11] United States Round Robin Questions [00:46:27] Respondent Opening Statement [00:48:55] Respondent Free for All Questions [01:16:48] Respondent Round Robin Questions [01:16:58] Petitioner Rebuttal

Opinion Summary: Abouammo v. United States | Trial on Home Turf Not Government's Pick

FS Credit Opportunities Corp. v. Saba Capital Master Fund, Ltd. | Case No. 24-345 | Docket Link: Here [https://www.supremecourt.gov/docket/docketfiles/html/public/24-345.html] | Argued: 12/10/2025 | Decided: 06/11/2026 Overview: The Investment Company Act case addresses whether Section 47(b) grants private parties the right to sue for contract rescission, testing the limits of implied private rights of action against a comprehensive SEC enforcement scheme. Question Presented: Whether Section 47(b) of the Investment Company Act impliedly empowers private parties to sue for contract rescission. Posture: District Court granted Saba summary judgment; Second Circuit summarily affirmed; Supreme Court reversed. Main Arguments: * Petitioner (the Funds): * (1) Section 47(b) directs courts on remedy application, not individuals on rights to sue — it lacks rights-creating language aimed at a particular class under Sandoval; * (2) The ICA's comprehensive SEC enforcement scheme and two express private rights of action elsewhere in the statute foreclose implied private enforcement; * (3) Congress's 1980 deletion of "shall be void" — the precise textual basis TAMA relied on — signals changed meaning and eliminates the implied right. * Respondent (Saba): * (1) Congress inserted "rescission" and "any party" into Section 47(b) in 1980, language presupposing an affirmative private right for both contract parties; * (2) TAMA's unanimous rescission holding survives the 1980 amendments, which refined rather than eliminated the private right; * (3) House and Senate Committee Reports expressly called for courts to imply private rights of action under the amended ICA. Holding: Section 47(b) of the ICA does not impliedly empower private parties to sue for rescission of contracts that allegedly violate the Act. Voting Breakdown: 6-3. Justice Barrett wrote the majority opinion joined by Chief Justice Roberts and Justices Thomas, Alito, Gorsuch, and Kavanaugh. Justice Kagan filed a dissenting opinion. Justice Jackson filed a dissenting opinion joined by Justice Sotomayor, with Justice Kagan joining Parts I and II. Reversed and remanded. Opinion: Here [https://www.supremecourt.gov/opinions/25pdf/25-5146_e29f.pdf] Majority Reasoning: * (1) Section 47(b)'s "a court may not deny rescission" language directs courts on remedy — it lacks rights-creating language aimed at a particular class of persons under Sandoval; * (2) The ICA's comprehensive SEC enforcement scheme and two express private rights of action elsewhere in the statute foreclose implied private enforcement; * (3) Congress's 1980 deletion of "shall be void" — the TAMA linchpin — signals changed meaning and removes the textual foundation for a private right. Separate Opinions: * Justice Kagan (dissenting alone): Agrees with Jackson's text-and-structure analysis that Section 47(b) supports a private right; declines to rely on legislative history, finding the provision not sufficiently ambiguous to require resort to committee reports. * Justice Jackson (dissenting, joined by Justice Sotomayor; Justice Kagan joins Parts I and II): Congress inserted "rescission" and "any party" into the 1980 amendments to preserve TAMA's rescission right; post-performance context makes affirmative suit the only practical remedy; Committee Reports expressly called for continued implied rights under the amended ICA. Implications: * (1) Activist investors lose the federal right to challenge closed-end fund governance under Section 47(b); the SEC remains the exclusive enforcer; * (2) Closed-end funds gain protection from private ICA rescission suits; state control-share adoption receives implicit judicial validation; * (3) The Court extends textualist limits on implied private rights of action, tightening Sandoval's framework further into securities law. The Fine Print: * Section 47(b)(2), 15 U.S.C. §80a-46(b)(2): "a court may not deny rescission at the instance of any party unless such court finds that under the circumstances the denial of rescission would produce a more equitable result than its grant and would not be inconsistent with the purposes of this subchapter." * Section 18(i), 15 U.S.C. §80a-18(i): "every share of stock hereafter issued by a registered management company . . . shall be a voting stock and have equal voting rights with every other outstanding voting stock." Primary Cases: * Alexander v. Sandoval (2001): Courts infer implied private rights of action only where a statute uses rights-creating language aimed at a particular class of persons; language directing courts or agencies falls short. * Transamerica Mortgage Advisors, Inc. v. Lewis (1979): The Investment Advisers Act's "shall be void" language created an implied private right of action for rescission; all nine justices agreed on that point. Oral Advocates: * Petitioner (Abouammo): Tobias Loss-Eaton of Sidley Austin * Respondent (United States): Anthony A. Yang, Assistant to the Solicitor General, Department of Justice.