On June 18, 2026, the Supreme Court issued a 5-4 decision in T.M. v. University of Maryland Medical Systems, concluding that the long-maligned Rooker-Feldman doctrine strictly bars a federal court collateral attack on a state court judgment, even when that judgment remains subject to further review in the state’s appellate courts. The Court resolved a circuit split over when the doctrine attaches and reaffirmed that litigants generally cannot use a federal district court as an alternative forum to challenge an adverse state court judgment while state appellate proceedings remain available. Although the Court described its holding as a narrow application of existing precedent, the decision reinforces the doctrine’s continued vitality.

The Supreme Court recently decided Enbridge Energy, LP v. Nessel (No. 24-783), holding that the equitable tolling doctrine cannot be invoked to extend the 30-day deadline for removing a case from state to federal court under 28 U.S.C. § 1446. The decision clarifies the finality of removal decisions and reinforces the availability of federal jurisdiction based on the procedural framework Congress enacted—not equitable exceptions fashioned by the courts.

In Wolford v. Lopez (24-1046), the Supreme Court addressed whether a state may prohibit carrying firearms on others’ private property open to the public without the owners’ permission. In a 6-3 decision, the Court held that Hawaii violated the Second and Fourteenth Amendments by prohibiting individuals licensed to carry concealed handguns from doing so without first receiving the property owner’s express authorization. Justice Alito authored the majority opinion, joined by Chief Justice Roberts and Justices Thomas, Gorsuch, Kavanaugh, and Barrett. Additionally, Justice Barrett filed a concurrence, joined by Justices Thomas and Gorsuch as to Part II-B. Justice Kagan dissented, and Justice Jackson filed a separate dissent joined by Justice Sotomayor.