T. M. v. University of Md. Medical System Corporation · ¶42

Finally, T. M. contends that the Court should adopt her position for the more practical reason that it will generally cabin Rooker-Feldman, a doctrine she claims has caused confusion and is overused as a docket-clearing mechanism in the lower courts. See Brief for Petitioner 35. As T. M. admits, however, most of the confusion in the lower courts “stems from the need to determine when a plaintiff is seeking federal ‘review and rejection’ of a state-court judgment.” Id., at 37; see Gilbank v. Wood Cty. Dept. of Human Servs., 111 F. 4th 754, 792–798 (CA7 2024) (en banc) (majority opinion of Kirsch, J.); id., at 760, 769–778 (dissenting opinion of Hamilton, J.) (describing the confusion over the “‘review and rejection’” requirement). That “review and rejection” question is not disputed in this case, so adopting T. M.’s rule does nothing to ameliorate any confusion over that distinct issue.

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