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T. M. v. University of Md. Medical System Corporation · ¶108

Yet even as it resuscitates the §1331 rationale, the Court acknowledges that §1257 remains in the mix. Ante, at 6 (describing Rooker-Feldman as “built” on both §1331 and §1257). And by recognizing that the doctrine applies only to “state-court judgments,” ante, at 1 (emphasis added), the Court tacitly admits that §1257—not §1331—is what really determines when Rooker-Feldman kicks in. Still, the Court’s embrace of §1257 is only partial: It is unwilling to accept §1257’s requirement of a “[f]inal judgment” from the “highest court of a State.” The Court’s main reason for disregarding this limit appears to be Exxon, but as explained, Exxon compels the opposite conclusion.
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