V.L. v. E.L.

LOCATION: Superior Court of Fulton County, Georgia

DOCKET NO.: 15-648
DECIDED BY: Roberts Court (2016- )
LOWER COURT: Supreme Court of Alabama

CITATION: 577 US (2016)
GRANTED: Mar 07, 2016
DECIDED: Mar 07, 2016

Facts of the case

V.L. and E.L., a lesbian couple, were in a long-term relationship and raised three children together, of which E.L. was the biological parent. They eventually decided that V.L. should adopt the children and filed a petition to do so in Georgia state court, which granted the petition. In 2011, while living in Alabama, V.L. and E.L. ended their relationship. V.L. filed a petition in Alabama state court that alleged the E.L. had denied her access to her children and interfered with her parental rights. V.L. asked the Alabama state court to register the Georgia adoption judgment and order custody or visitation, which the court did, and E.L. appealed. The Alabama Court of Civil Appeals held that the lower court had failed to conduct an evidentiary hearing. The Alabama Supreme Court reversed and held that the Georgia state court did not have subject-matter jurisdiction to enter an adoption order for V.L. while still recognizing E.L.’s parental rights and therefore the Alabama courts did not have to recognize that judgment under the Full Faith and Credit Clause.


Does the Full Faith and Credit Clause of the Constitution require that the Alabama state courts recognize a Georgia state court’s adoption order?