V.L. v. E.L.

Supreme Court of the United States

136 S. Ct. 1017 (2016)

A final judgment in one state rendered by a court of competent jurisdiction must be enforced by courts of other states.

Relevant Facts

V.L. (the plaintiff) and E.L. (the defendant) were in a long-term relationship. The couple decided to have a child, and the defendant gave birth. Additionally, the defendant later gave birth to twins as well. The couple raised the three children together. A Georgia court entered an adoption order, appointing the plaintiff as the children’s legal parent. The couple then moved to Alabama and later separated. The plaintiff petitioned an Alabama court to enforce the Georgia court’s adoption ruling, seeking custody or visitation rights.

The Circuit Court of Jefferson County awarded the plaintiff visitation rights. The Alabama Supreme Court reversed, declining to enforce the Georgia ruling because 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. The United States Supreme Court granted the plaintiff’s petition for certiorari.

Issue

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Holding & Reasoning

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Concurrence

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Dissent

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Last updated:

December 12, 2020

Judicial Opinion

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Procedural History

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Citations

136 S. Ct. 1017 (2016)