T. M. v. University of Md. Medical System Corporation · ¶98

None of this is to say that Rooker-Feldman is inconsequential. Crucially, it is jurisdictional—so courts must analyze it, even if no one raises it. And because Rooker-Field man lacks both a clear role and a clear rationale, it is hard to contain. After Feldman, the doctrine became “perhaps the primary docket-clearing workhorse for the federal courts.” S. Bandes, The Rooker-Feldman Doctrine: Evaluating Its Jurisdictional Status, 74 Notre Dame L. Rev. 1175 (1999). “In the process,” Rooker-Feldman “mushroomed well beyond the §1257 explanation that gave it birth, as the federal courts found one claim after another closely intertwined with claims raised, resolved, sometimes still pending, in the state courts.” VanderKodde v. Mary Jane M. El liott, P. C., 951 F. 3d 397, 406 (CA6 2020) (Sutton, J., concurring).

preliminary print (page proof)
Source edition
Passage preview. Read in context for the complete text, notes and references.