Professor Samuel Bray's scholarship was cited by Justice Amy Coney Barrett in a dissenting opinion issued today, marking the third time this Term that Bray’s scholarship has appeared in a US Supreme Court opinion.

The citation came in in T. M. v. University of Maryland Medical System Corp., a case concerning the scope of the Rooker-Feldman doctrine, a rule that limits federal district court review of certain state-court judgments. In a 5–4 decision, the Court held that the doctrine barred the federal lawsuit at issue in the case.

In her dissent, Barrett discussed the Supreme Court’s 2005 decision in Exxon Mobil Corp. v. Saudi Basic Industries Corp., which significantly narrowed the reach of the Rooker-Feldman doctrine. Citing Bray’s 2006 Green Bag article, “Rooker Feldman (1923–2006),” Barrett observed that the Court’s rejection of the doctrine was so vigorous that “one scholar penned its obituary.”

The citation is the latest example of the Supreme Court engaging with Bray’s scholarship. Earlier this month, Justice Clarence Thomas cited Bray’s work nine times in a concurring opinion in Sripetch v. Securities and Exchange Commission. Last February, Bray’s scholarship was cited by Justice Brett Kavanaugh in his dissent in Learning Resources, Inc., et al. v. Trump.