v.L. v. E.L.

136 S.Ct. 1017 (2016)

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Nature of the Case

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Facts

V. L. and E. L. are two women who were in a relationship from approximately 1995 until 2011. 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. V. L. and E. L. decided to give legal status to the relationship between V. L. and the children by having V. L. formally adopt them. V. L. then filed an adoption petition in the Superior Court of Fulton County, Georgia. E. L. also appeared 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. V. L. and E. L. ended their relationship in 2011 while living in Alabama. V. L. 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. V.L. asked the Alabama court to register the Georgia adoption judgment and award her some measure of custody or visitation rights. The Family Court entered an order awarding V. L. scheduled visitation with the children. E. L. appealed. She argued, among other points, that the Alabama courts should not recognize the Georgia judgment because the Georgia court lacked subject-matter jurisdiction to enter it. The Court of Civil Appeals rejected that argument. It held 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. The 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. It held that Alabama courts were not required to accord full faith and credit to the Georgia judgment. The Supreme Court granted certiorari.