## Facts

- V.L. and E.L. were in a long-term same-sex relationship and raised three children born to E.L. through assisted reproductive technology.
- In 2007, V.L. petitioned the Superior Court of Fulton County, Georgia, to adopt the children as a “second parent.”
- E.L. appeared in the Georgia proceeding and expressly consented to the adoption without relinquishing her own parental rights.
- The Georgia court entered a final adoption decree recognizing both V.L. and E.L. as the children’s legal parents and stating it had jurisdiction over the subject matter and the parties.
- After the couple separated in Alabama, V.L. sought to register the Georgia adoption judgment and obtain custody/visitation relief.
- An Alabama family court awarded V.L. scheduled visitation.
- The Alabama Supreme Court later held the Georgia decree void, concluding the Georgia court lacked subject-matter jurisdiction because it allegedly misapplied Georgia adoption statutes, and therefore refused to give the decree full faith and credit.

## Issues

1. Whether the Full Faith and Credit Clause requires Alabama to recognize a final Georgia adoption judgment issued by a court of general jurisdiction.
2. Whether an alleged misinterpretation of the rendering state’s adoption statutes can be treated as a subject-matter jurisdiction defect permitting nonrecognition.

## Decision

- The U.S. Supreme Court unanimously (per curiam) summarily reversed the Alabama Supreme Court.
- The Court held Alabama must give full faith and credit to the Georgia adoption decree.
- The Court ruled Alabama could not refuse recognition based on disagreement with Georgia’s application of its own adoption statutes.
- The case was remanded for proceedings consistent with the requirement that the Georgia judgment be recognized and given effect.

## Legal Principles

- A final judgment rendered by a court with adjudicatory authority over the subject matter and the parties must be recognized by other states under the Full Faith and Credit Clause.
- A state may not disregard a sister-state judgment because it believes the judgment is legally erroneous on the merits.
- When a judgment appears on its face to have been issued by a court of competent jurisdiction, jurisdiction is presumed; the challenger bears the burden to show lack of jurisdiction.
- The full-faith-and-credit jurisdictional inquiry is limited; courts may not repackage merits questions (e.g., statutory interpretation) as jurisdictional defects.
- Under Georgia law, superior courts have exclusive jurisdiction over adoption matters; alleged errors in applying adoption statutes do not negate that subject-matter jurisdiction.

## Conclusion

The Court required Alabama to recognize and give effect to Georgia’s second-parent adoption decree, holding that full faith and credit cannot be denied on the theory that the Georgia court misapplied Georgia adoption law where the rendering court had adjudicatory authority over adoptions and the parties.


V.L. v. E.L., 577 U.S. 404 (2016)