A woman from Maryland, referred to as “T.M.,” is at the center of a legal battle against a Baltimore hospital over allegations of wrongful confinement and forced medication. The Supreme Court is set to hear her case, which raises questions about the boundaries of federal oversight in the context of state court decisions. At the heart of the matter is T.M.’s involuntary commitment and the administration of antipsychotic drugs against her will, despite evaluations from independent experts indicating she did not require inpatient care.
T.M. suffers from a rare autoimmune condition known as Hashimoto’s thyroiditis, coupled with non-celiac gluten sensitivity. This combination can trigger severe psychological episodes if gluten is ingested. In 2023, after experiencing a gluten-induced psychotic episode, T.M. sought voluntary admission to the Baltimore Washington Medical Center. However, hospital staff denied her request and chose instead to commit her involuntarily, without notifying her father, who was designated to make health care decisions on her behalf.
According to court documents, T.M. was not deemed a danger to herself or others, yet the psychiatrist overseeing her case, Dr. Thomas Cummings, speculated that if released, she might neglect her medication and ultimately end up back in the hospital. Following this assessment, Cummings secured permission from an administrative judge to forcibly administer antipsychotic medication to T.M.
Despite passing evaluations from outside psychiatrists who concluded that she did not need the intensive care being provided, T.M. remained hospitalized until June 2023. At that time, she signed a state court consent order for release, which mandated that she change healthcare providers, refrain from suing the hospital, and continue with regular medication injections. Furthermore, her parents were instructed to notify authorities if she failed to adhere to her new treatment plan.
Feeling coerced into signing the consent order, T.M. later filed a federal lawsuit claiming that the order placed unconstitutional limits on her ability to control her healthcare. Her suit argued that she had entered into the agreement under duress, rendering it invalid and unenforceable. As the federal lawsuit progressed, T.M. sought to pause proceedings in state court until her federal case could be resolved.
However, the U.S. District Court for the District of Maryland dismissed her lawsuit based on the Rooker-Feldman doctrine, which restricts lower federal courts from reviewing final decisions made by state courts. The district court ruled that T.M.’s consent order was final, as she had stayed her state appeal, labeling her a “state court loser.” Judge Stephanie A. Gallagher noted, “Because her relief lies in the state courts, she cannot avoid Rooker-Feldman simply by bypassing those courts.”
Disputing this interpretation, T.M. contended that her case was still pending in state courts, making it active and available for federal review. This led her to appeal Gallagher’s decision to the 4th Circuit Court of Appeals. In June 2025, the circuit court sided with the lower court, effectively barring T.M. from contesting the constitutionality of the consent order in federal court. T.M. subsequently escalated her appeal to the Supreme Court, which has agreed to hear her case.
The Supreme Court will consider whether the Rooker-Feldman doctrine applies to a case where a state court decision remains open to further review. The Constitutional Accountability Center, a Washington D.C.-based think tank, argues that extending the doctrine in this context would contradict Congressional intent to facilitate federal access for the enforcement of rights. In an amicus brief filed on behalf of T.M., the center asserted, “The Supreme Court has never applied the Rooker-Feldman doctrine in a case like this one, where the state-court judgment is still subject to further review.” It claimed that the doctrine was meant to be narrowly applied to “final decisions of state courts of last resort.”
A decision in T.M.’s favor could allow her to challenge the consent order in federal court, offering her a pathway to regain autonomy over her healthcare decisions that she argues were compromised during her hospitalization. The implications of the Supreme Court’s ruling could resonate broadly, affecting how federal courts engage with state decisions, particularly in healthcare-related matters.
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