V.L. v. E.L.
The Supreme Court reversed the Alabama Supreme Court, ruling that Alabama had to honor a Georgia adoption decree recognizing a woman as a legal parent of the children she had raised with her former partner.
The decision reinforces that states generally cannot second-guess another state's court judgments just because they disagree with how that court applied its own law, protecting the finality of adoption decrees for families who move across state lines.
How it got here: An Alabama family court granted V. L. visitation; the Alabama Court of Civil Appeals remanded for a hearing; the Alabama Supreme Court reversed, refusing to recognize the Georgia adoption, prompting this appeal.
The Case in Depth
What happened
V. L. and E. L., a same-sex couple, raised three children together that E. L. had given birth to through assisted reproduction. To give V. L. legal parental status, the couple obtained a Georgia court's adoption decree recognizing V. L. as a second legal parent while E. L. kept her own parental rights. After the couple separated while living in Alabama, V. L. sought to have Alabama enforce the Georgia adoption and grant her custody or visitation.
The question before the Court
Could Alabama refuse to recognize a Georgia court's adoption order that made two women joint legal parents of their children?
Why it matters
Families formed through adoption in one state, including same-sex couples who used a state's adoption process to secure both parents' legal rights, can rely on that adoption being honored if they move to another state. The ruling prevents states from using disagreements over another state's adoption law as a backdoor to strip a parent of custody or visitation rights.
What changes now
The case is sent back to the Alabama courts, which must now honor the Georgia adoption judgment and address V. L.'s request for custody or visitation on that basis rather than questioning the adoption's validity. This is a final ruling on the full faith and credit question, though further proceedings in Alabama will determine the specific custody or visitation arrangements.
What this does not decide
The Court did not decide whether the Georgia adoption was correctly decided under Georgia law, only whether the Georgia court had jurisdiction to enter it. It also did not rule on the merits of any custody or visitation arrangement, leaving those questions for further Alabama court proceedings.
How the Court got there
The legal reasoning, step by step
- The Court applied the Full Faith and Credit Clause, which requires every state to recognize valid judgments from another state's courts, and explained that a state may only refuse recognition if the issuing court lacked jurisdiction over the subject matter or the parties.
- The Court noted that this jurisdictional inquiry is narrow: if a judgment appears on its face to come from a court of general jurisdiction, that jurisdiction is presumed unless disproved by the record or other evidence.
- Applying Georgia law, the Court found that a Georgia statute expressly gives superior courts 'exclusive jurisdiction in all matters of adoption,' which plainly covered the adoption petition the Georgia court decided.
- The Court rejected Alabama's theory that a separate Georgia statute limiting who may be adopted (requiring existing parents to surrender their rights) was jurisdictional rather than a rule for deciding the merits, noting no Georgia court had ever read that provision as jurisdictional.
- The Court explained that a requirement does not become jurisdictional merely because it is mandatory and must be strictly construed, since many mandatory legal rules go to the merits of a case rather than a court's power to hear it.
- Because the Georgia judgment appeared valid on its face and nothing in Georgia law rebutted the presumption of jurisdiction, the Court concluded Alabama was required to give the adoption decree full faith and credit.
Doctrinal impact
Cases affected by this decision
Reaffirms Milliken v. Meyer (311 U. S. 457)
Relied on to presume a sister state's judgment is valid unless jurisdiction is disproved.
Reaffirms Baker v. General Motors Corp. (522 U. S. 222)
Used to confirm that a final judgment from a court with proper authority must be recognized nationwide.