V.L. v. E.L.
The Supreme Court summarily reversed the Alabama Supreme Court, ruling that Alabama had to honor a Georgia adoption decree that gave a woman legal parental rights to the children she and her former partner had raised together.
The Court held that the Full Faith and Credit Clause required Alabama courts to respect the Georgia judgment because the Georgia court had jurisdiction to decide adoption cases, even if Alabama disagreed with how Georgia law was applied.
“the full faith and credit clause of the Constitution precludes any inquiry into the merits of the cause of action, the logic or consistency of the decision, or the validity of the legal principles on which the judgment is based.”
The Court explains that states cannot second-guess the reasoning behind a sister state's judgment.
How it got here: An Alabama family court awarded V.L. visitation; Alabama's Court of Civil Appeals remanded for a hearing, but the Alabama Supreme Court reversed and refused to recognize the Georgia adoption.
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. The couple arranged for V.L. to formally adopt the children in Georgia, with E.L.'s consent and without giving up her own parental rights. After the couple separated while living in Alabama, V.L. sought custody or visitation, and E.L. contested V.L.'s parental status.
The question before the Court
Did Alabama have to recognize a Georgia court's adoption decree that had made a same-sex partner a legal parent of her partner's children?
Why it matters
The ruling protects parents — including many in same-sex couples — who adopted children in one state from losing their parental rights simply by moving to another state that might have decided the adoption differently. It reinforces that state courts generally cannot second-guess a sister state's adoption judgment, giving families more certainty when they relocate.
What changes now
The case is sent back to the Alabama courts, which must now recognize V.L. as a legal parent under the Georgia adoption judgment and proceed with her custody or visitation request on that basis. The ruling is a final resolution of the full faith and credit question, though further proceedings on the specific custody and visitation arrangements will continue in the lower courts.
What this does not decide
The Court did not decide whether Georgia's adoption law was correctly applied or whether V.L.'s adoption was substantively proper under Georgia law. It decided only that Alabama could not refuse to recognize the Georgia judgment based on a disagreement over how that law was applied.
How the Court got there
The legal reasoning, step by step
- The Court applied the Full Faith and Credit Clause, which requires each state to recognize a final judgment from another state's court as long as that court had authority over the subject matter and the parties involved.
- Under this rule, a court may only look into whether the issuing court had that authority in the first place — it cannot re-examine whether the judgment was correct on the merits.
- A Georgia statute gave Georgia's superior courts 'exclusive jurisdiction in all matters of adoption,' which on its face gave the Georgia court authority to decide the adoption petition.
- The Alabama Supreme Court had instead relied on a separate Georgia statute requiring existing parents to surrender their rights before a third party could adopt, treating that requirement as jurisdictional rather than as a rule for deciding the case.
- The Court explained that a legal requirement being mandatory or strictly enforced does not automatically make it jurisdictional, and no Georgia court had ever read that particular statute as limiting the adoption court's power to hear the case.
- Because the Georgia judgment appeared valid on its face and nothing rebutted the presumption that the Georgia court had jurisdiction, Alabama was constitutionally required to give the judgment full faith and credit.
Doctrinal impact
Cases affected by this decision
Reaffirms Milliken v. Meyer (311 U.S. 457)
Relied on for the rule that a judgment's jurisdiction is presumed valid unless disproved.
Reaffirms Baker v. General Motors Corp. (522 U.S. 222)
Cited for the rule that full faith and credit obligations for judgments are exacting.