V.L. v. E.L.

Background

Two women lived together and raised three children conceived through assisted reproductive technology. In Georgia, one woman formally adopted the children with the other woman’s written consent, and the Georgia Superior Court entered a final adoption judgment naming both women as legal parents. After the couple separated while living in Alabama, the adoptive parent asked Alabama courts to register the Georgia judgment and enforce custody or visitation rights. The Alabama Supreme Court refused to recognize the Georgia judgment, saying Georgia law required parents to surrender rights and that this made the Georgia court lack subject‑matter jurisdiction.

Reasoning

The Constitution requires states to respect valid judgments from other states when the issuing court had authority over the subject and the people involved. The Supreme Court explained that Georgia law gives its Superior Courts exclusive authority over adoptions, and the Georgia adoption decree on its face came from a court of general jurisdiction. A Georgia statute about when adoptions should be allowed does not itself make the Georgia court lack jurisdiction. Because nothing disproved the usual presumption that the Georgia court had jurisdiction, Alabama should have given full effect to the Georgia judgment. The Supreme Court reversed the Alabama Supreme Court and sent the case back for further steps consistent with this ruling.

Real world impact

The decision means that out‑of‑state adoption orders that appear to come from a court with proper authority generally must be honored by other states. That protects co‑parents and families who move between states by keeping established parental rights intact. The case was reversed and remanded for further proceedings consistent with the Court’s conclusion.