V.L. v. E.L.
136 S. Ct. 1017, 194 L. Ed. 2d 92 (2016)
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Rule of Law:
The Full Faith and Credit Clause of the U.S. Constitution requires a state to enforce a final judgment from another state, so long as the rendering court had subject-matter jurisdiction over the case. A state cannot refuse to recognize a judgment by reinterpreting the rendering state's substantive laws as jurisdictional limits.
Facts:
- V.L. and E.L., two women, were in a long-term relationship from approximately 1995 to 2011.
- Through assisted reproductive technology, E.L. gave birth to three children, in 2002 and 2004, whom the couple raised together as joint parents.
- The couple decided that V.L. should legally adopt the children to formalize her parental status.
- To facilitate the adoption, the couple established residency in Georgia, where V.L. filed an adoption petition in the Superior Court of Fulton County.
- E.L. appeared in the Georgia proceeding and gave her express consent for V.L. to adopt the children as a second parent without E.L. relinquishing her own parental rights.
- The Georgia Superior Court entered a final decree of adoption, recognizing both V.L. and E.L. as the children's legal parents.
- In 2011, the couple ended their relationship while living in Alabama.
Procedural Posture:
- After the couple's separation in Alabama, V.L. filed a petition in an Alabama trial court (Circuit Court of Jefferson County) to register the Georgia adoption decree and grant her custody or visitation.
- The case was transferred to the Family Court of Jefferson County, which entered an order granting V.L. scheduled visitation with the children.
- E.L. (as appellant) appealed to the Alabama Court of Civil Appeals, arguing that the Georgia court lacked subject-matter jurisdiction for the adoption.
- The Court of Civil Appeals rejected the jurisdictional argument but remanded for an evidentiary hearing on visitation.
- E.L. appealed to the Alabama Supreme Court, which reversed the lower appellate court.
- The Alabama Supreme Court held that the Georgia court lacked subject-matter jurisdiction, and therefore, Alabama courts were not required to give the Georgia adoption judgment full faith and credit.
- 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 require Alabama courts to recognize a Georgia adoption judgment when the Alabama Supreme Court concluded the Georgia court lacked subject-matter jurisdiction because it allegedly misapplied Georgia's substantive adoption statutes?
Opinions:
Majority - Per Curiam
Yes. The Full Faith and Credit Clause requires Alabama to recognize the Georgia adoption judgment. A final judgment rendered by a court with jurisdiction over the subject matter and the parties is entitled to recognition throughout the nation. A state may not disregard another state's judgment because it disagrees with the merits or the legal reasoning. The only exception is for a lack of jurisdiction, but the inquiry into jurisdiction is limited. Here, Georgia law explicitly grants its superior courts 'exclusive jurisdiction in all matters of adoption.' The Alabama Supreme Court erred by concluding that a different Georgia statute, which outlines substantive requirements for adoption, acted as a jurisdictional bar. That statute, which concerns the surrender of parental rights, is a rule of decision for the merits, not a limit on the court's power to hear the case. Because the Georgia court had jurisdiction over the general class of adoption cases, its judgment is entitled to full faith and credit.
Analysis:
This decision strongly reaffirms the 'exacting' nature of the Full Faith and Credit Clause, particularly in the context of family law judgments. It clarifies the critical distinction between a court's subject-matter jurisdiction (its power to hear a type of case) and its application of substantive law on the merits. The ruling prevents states from using a disagreement with another state's laws or legal conclusions as a pretext for denying recognition of a valid final judgment. This precedent is especially significant for ensuring the portability of parental rights, providing stability for families, including those of same-sex couples, as they move between states.
