Law School Case Brief
V.L. v. E.L. - 136 S. Ct. 1017 (2016)
A state is not required to afford full faith and credit to a judgment rendered by a court that did not have jurisdiction over the subject matter or the relevant parties. Consequently, before a court is bound by a judgment rendered in another state, it may inquire into the jurisdictional basis of the foreign court’s decree. That jurisdictional inquiry, however, is a limited one. If the judgment on its face appears to be a record of a court of general jurisdiction, such jurisdiction over the cause and the parties is to be presumed unless disproved by extrinsic evidence, or by the record itself.
L. and E. L. are two women who were in a relationship from approximately 1995 until 2011. Through assisted reproductive technology, E. L. gave birth to a child named S. L. in 2002 and to twins named N. L. and H. L. in 2004. After the children were born, V. L. and E. L. raised them together as joint parents. A Georgia court entered a final judgment of adoption making petitioner V. L. a legal parent of the children, but the parties subsequently separated and V. L. asked the Alabama courts to enforce the Georgia judgment and grant her custody or visitation rights. The Alabama Supreme Court ruled against her, holding that the Full Faith and Credit Clause of the United States Constitution does not require the Alabama courts to respect the Georgia judgment.
Is the Georgia judgment granting custody and visitation rights to V.L. jurisdictional?
The Alabama Supreme Court erred in refusing to grant full faith and credit to a Georgia court's judgment of adoption making petitioner a legal parent of the children that she and respondent had raised together where neither the statute upon which it relied, nor the Georgia courts indicated that the statute was jurisdictional, and thus, there was nothing to rebut the presumption that the Georgia judgment was issued by a court with jurisdiction.
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