V.L. v. E.L.

Brief Fact Summary.

Plaintiff and Defendant were two women in a romantic relationship. During their relationship, Defendant gave birth to three children, whom the couple raised together as joint parents. A Georgia court entered a final judgment of adoption making Plaintiff a legal parent of the children. The parties subsequently separated while they were living in Alabama. Plaintiff filed a petition against Defendant, asking the Alabama courts to enforce the Georgia judgment and grant her custody or visitation rights. The Alabama Supreme Court ruled against her.

Synopsis of Rule of Law.

A final judgment in one state, if rendered by a court of competent jurisdiction (both over the subject matter and the persons governed by the judgment), must be enforced by courts of other states.

Facts.

Plaintiff and Defendant, two women, were in a long-term relationship. The couple decided to have a child, and Defendant subsequently gave birth to three kids. The couple raised the three children together. A Georgia court entered an adoption order, making Plaintiff the children’s legal parent. The couple moved to Alabama and later separated. Plaintiff petitioned an Alabama court to enforce the Georgia court’s adoption ruling. Plaintiff sought custody or visitation rights. The Circuit Court of Jefferson County awarded Plaintiff visitation rights. The Alabama Supreme Court reversed, declining to enforce the Georgia ruling on the ground that the Georgia court did not have subject-matter jurisdiction over the adoption due to a Georgia law prohibiting adoption of a child with a living parent unless the living parent surrendered her rights to the child.

Issue.

Does the Full Faith and Credit Clause of the Constitution require that the Alabama state courts recognize a Georgia state court’s adoption order?

Held.

Yes. The court reversed the judgment of the Alabama Supreme Court and remanded the case, holding that a state may only refuse to afford full faith and credit to another state’s judgment if that court did not have subject-matter jurisdiction or personal jurisdiction over the relevant parties.

Discussion.

A final judgment in one state, if rendered by a court of competent jurisdiction (both over the subject matter and the persons governed by the judgment), must be enforced by courts of other states. A state is not required to afford full faith and credit to another state court’s judgment if that state court did not have subject-matter jurisdiction or personal jurisdiction over the relevant parties. However, the jurisdictional inquiry is limited. In other words, if the judgment appears at face value to be a record of a court of general jurisdiction, then the court is presumed to have competent jurisdiction over the subject matter and the parties, unless disproved by extrinsic evidence or by the record itself. Unless an issue is clearly jurisdictional, courts should be hesitant about labeling a matter jurisdictional so as not to reopen disputes that have been finalized.

Here, the Alabama Supreme Court erred by ruling in favor of Defendant and declining to enforce the Georgia’s adoption judgment. The judgment on its face was by a court of general jurisdiction. Georgia law gives the state courts jurisdiction over adoption cases, and there is no established Georgia rule to the contrary. Defendant did not rebut that presumption that Georgia state court had competent jurisdiction. In addition, although the Georgia’s judgment may have been decided incorrectly on the merits, such mistake was not for wont of jurisdiction. The Alabama Supreme Court erred by labeling the issue jurisdictional and not giving full faith and credit to the Georgia’s judgment. Therefore, Alabama courts must give full faith and credit to Georgia’s final judgment. For these reasons, the Alabama Supreme Court’s judgment was reversed, and the case was remanded.