V.L. v. E.L.
577 U. S. ____ (2016) (2016)
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Rule of Law:
Under the Full Faith and Credit Clause, a state may not refuse to recognize a final judgment from a sister state's court by concluding that the judgment-issuing court misapplied its own state's substantive law, as such a disagreement on the merits does not defeat the original court's subject-matter jurisdiction.
Facts:
- V.L. and E.L., two women, were in a long-term relationship from approximately 1995 until 2011.
- Through assisted reproductive technology, E.L. gave birth to three children, in 2002 and 2004.
- V.L. and E.L. raised the children together as joint parents.
- To formalize V.L.'s parental status, the couple traveled to Georgia, where V.L. petitioned to adopt the children.
- With E.L.'s express consent and without terminating E.L.'s own parental rights, a Georgia Superior Court entered a final decree of adoption making V.L. a legal parent of the children.
- In 2011, the couple separated while living in Alabama.
- Following the separation, E.L. denied V.L. access to the children.
Procedural Posture:
- V.L. filed a petition in the Circuit Court of Jefferson County, Alabama, to register the Georgia adoption judgment and seek custody or visitation.
- The case was transferred to the Family Court of Jefferson County, which entered an order awarding V.L. scheduled visitation.
- E.L. appealed the visitation order to the Alabama Court of Civil Appeals, which remanded the case for an evidentiary hearing but rejected E.L.'s jurisdictional argument.
- The Alabama Supreme Court granted review and reversed the lower court, holding that Alabama was not required to give full faith and credit to the Georgia judgment.
- V.L. petitioned the U.S. Supreme Court for a writ of certiorari.
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Issue:
Does the Full Faith and Credit Clause of the U.S. Constitution require an Alabama court to recognize a Georgia adoption judgment when the Alabama court concludes that the Georgia court misapplied Georgia's adoption statute in granting the adoption?
Opinions:
Majority - Per Curiam
Yes. The Full Faith and Credit Clause requires Alabama to recognize the Georgia judgment because a state cannot refuse to enforce another state's final judgment based on a disagreement with the merits or legal reasoning of that judgment. The Constitution's full faith and credit obligation is 'exacting' and requires a state to recognize a valid judgment rendered by a court with adjudicatory authority. A state may only disregard a sister state's judgment if the rendering court lacked subject-matter or personal jurisdiction. Here, Georgia law grants its superior courts 'exclusive jurisdiction in all matters of adoption.' The Alabama Supreme Court erred by treating a potential misapplication of a different Georgia statute—one setting out requirements for an adoption—as a jurisdictional defect. That statute is a rule of decision on the merits, not a limit on the court's fundamental power to hear the case. Mandatory statutory requirements are not automatically jurisdictional, and the Alabama court improperly inquired into the merits of the Georgia court's decision.
Analysis:
This decision strongly reaffirms the principle that the Full Faith and Credit Clause creates a nearly absolute obligation for states to recognize each other's judgments. It clarifies the narrowness of the jurisdictional exception, preventing states from using disagreements over another state's substantive law as a pretext to deny recognition. The ruling ensures the portability of parental rights established by adoption decrees, providing crucial stability for non-traditional families, particularly same-sex couples, whose parental status might otherwise be vulnerable to challenge in less favorable states. The case serves as a clear instruction to state courts to distinguish between a court's fundamental power to hear a case (jurisdiction) and its correctness in deciding it (merits).
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