E. L., ET AL
S.Ct. 1018] ON PETITION FOR WRIT OF CERTIORARI TO THE SUPREME
COURT OF ALABAMA
Kennedy, Thomas, Ginsburg, Breyer, Alito, Sotomayor, Kagan.
S.Ct. 1019] [194 L.Ed.2d 94] PER CURIAM.
Georgia court entered a final judgment of adoption making
petitioner V. L. a legal parent of the children that she and
respondent E. L. had raised together from birth. V. L. and E.
L. later separated while living in Alabama. 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. That judgment of the
Alabama Supreme Court is now reversed by this summary
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
and E. L. eventually decided to give legal status to the
relationship between V. L. and the children by having V. L.
formally adopt them. To facilitate the adoption, the couple
rented a house in Alpharetta, Georgia. V. L. then filed an
adoption petition in the Superior Court of Fulton County,
Georgia. E. L. also appeared [194 L.Ed.2d 95] in that
proceeding. While not relinquishing her own parental rights,
she gave her express consent to V. L.'s adoption of the
children as a second parent. The Georgia court determined
that V. L. had complied with the applicable requirements of
Georgia law, and entered a final decree of adoption allowing
V. L. to adopt the children and recognizing both V. L. and E.
L. as their legal parents.
and E. L. ended their relationship in 2011, while living in
Alabama, and V. L. moved out of the house that the couple had
shared. V. L. later filed a petition in the Circuit Court of
Jefferson County, Alabama, alleging that E. L. had denied her
access to the children and interfered with her ability to
exercise her parental rights. She asked the Alabama court to
register the Georgia adoption judgment and award her some
measure of custody or visitation rights. The matter was
transferred to the Family Court of Jefferson County. That
court entered an order awarding V. L. scheduled visitation
with the children.
appealed the visitation order to the Alabama Court of Civil
Appeals. She argued, among other points, that the Alabama
courts should not recognize the [136 S.Ct. 1020] Georgia
judgment because the Georgia court lacked subject-matter
jurisdiction to enter it. The Court of Civil Appeals rejected
that argument. It held, however, that the Alabama family
court had erred by failing to conduct an evidentiary hearing
before awarding V. L. visitation rights, and so it remanded
for the family court to conduct that hearing.
Alabama Supreme Court reversed. It held that the Georgia
court had no subject-matter jurisdiction under Georgia law to
enter a judgment allowing V. L. to adopt the children while
still recognizing E. L.'s parental rights. As a
consequence, the Alabama Supreme Court held Alabama courts
were not required to accord full faith and credit to the
Constitution provides that " Full Faith and Credit shall
be given in each State to the public Acts, Records, and
judicial Proceedings of every other State." U.S. Const.,
Art. IV, § 1. That Clause requires each State to
recognize and give effect to valid judgments rendered by the
courts of its sister States. It serves " to alter the
status of the several states as independent foreign
sovereignties, each free to ignore obligations created under
the laws or by the judicial proceedings of the others, and to
make them integral parts of a single nation."
Milwaukee County v. M. E. White Co., 296
U.S. 268, 277, 56 S.Ct. 229, 80 L.Ed. 220 (1935).
respect to judgments, " the full faith and credit
obligation is exacting." Baker v. General
Motors Corp., 522 U.S. 222, 233, 118 S.Ct. 657, 139
L.Ed.2d 580 (1998). " A final judgment in one State, if
rendered by a court with adjudicatory authority over the
subject matter and persons governed by the judgment,
qualifies for recognition throughout the land."
Ibid. A State may not disregard the judgment of a
sister State because it disagrees with the reasoning
underlying the judgment or deems it to be wrong on the
merits. On the contrary, " 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, [194 L.Ed.2d 96] or the validity of the legal
principles on which the judgment is based."
Milliken v. Meyer, 311 U.S. 457, 462, 61
S.Ct. 339, 85 L.Ed. 278 (1940).
State is not required, however, 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." Underwriters Nat. Assurance Co. v.
North Carolina Life & Accident & Health Ins.
Guaranty Assn., 455 U.S. 691, 705, 102 S.Ct. 1357, 71
L.Ed.2d 558 (1982). " 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." Ibid. That jurisdictional
inquiry, however, is a limited one. " [I]f 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