V.L. v. E.L.

Facts of the Case

L. and E. L. are two women who were in a relationship from approximately 1995 until 2011. Through assisted reproductive technology, E. L. gave birth to a child named S. L. in 2002 and to twins named N. L. and H. L. in 2004. After the children were born, V. L. and E. L. raised them together as joint parents. A Georgia court entered a final judgment of adoption making petitioner V. L. a legal parent of the children, but the parties subsequently separated and V. L. asked the Alabama courts to enforce the Georgia judgment and grant her custody or visitation rights. The Alabama Supreme Court ruled against her, holding that the Full Faith and Credit Clause of the United States Constitution does not require the Alabama courts to respect the Georgia judgment.

Question

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

CONCLUSION

The Full Faith and Credit Clause of the Constitution requires the Alabama state courts to recognize a Georgia state court’s adoption order. In a per curiam opinion, the Court held that a state may only refuse to afford full faith and credit to another state’s judgment if that court did not have subject-matter jurisdiction or jurisdiction over the relevant parties. In this case, Georgia law gives the state courts jurisdiction over adoption cases, and there is no established Georgia rule to the contrary, so the judgment should be afforded full faith and credit by other state courts.

Case Information

  • Citation: 577 US _ (2016)
  • Granted: Mar 7, 2016
  • Decided Mar 7, 2016