V.L. v. E.L., 577 U.S. 404

Georgia Superior Court entered final adoption decree making V. L. the legal parent and recognizing both V. L. and E. L. as parents.
E. L. consented to V. L.'s adoption as a second parent; Georgia law granted exclusive jurisdiction over adoptions to Georgia courts.
V. L. and E. L. separated in Alabama after adoption; V. L. sought to register the Georgia judgment and obtain custody/visitation in Alabama.
Alabama Family Court ordered scheduled visitation; E. L. appealed; Alabama Court of Civil Appeals remanded for an evidentiary hearing on visitation.
Alabama Supreme Court held Georgia lacked subject-matter jurisdiction under Ga. law to grant adoption while recognizing E. L.'s rights, denying full faith and credit.
U.S. Supreme Court granted certiorari; reversed Alabama Supreme Court, holding Georgia judgment had valid jurisdiction and should be given full faith and credit.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Alabama must give full faith and credit to the Georgia adoption decree	V. L. argues the Georgia court had jurisdiction and the decree valid.	E. L. contends Georgia lacked jurisdiction under Georgia law, thus no full faith and credit.	Yes; full faith and credit applies and Georgia decree is entitled to recognition.
Whether Georgia had subject-matter jurisdiction to enter the adoption decree	Georgia §19–8–2(a) grants exclusive adoption jurisdiction to Georgia courts.	Alabama relied on §19–8–5(a) to argue Georgia could not grant adoption while E. L. retained parental rights.	Georgia had adjudicatory authority; decree valid.
Whether §19–8–5(a) is a jurisdictional obstacle to the Georgia decree	N/A (E. L. disputes jurisdictional effect).	Georgia’s mandatory provisions are jurisdictional (as al. court held).	§19–8–5(a) is not jurisdictional; does not defeat jurisdiction.

Milliken v. Meyer, 311 U.S. 457 (1940) (presumption of jurisdiction when judgment facially from a court of general jurisdiction)
Adam v. Saenger, 303 U.S. 59 (1938) (jurisdictional presumption and facial validity standard)
Underwriters Nat. Assurance Co. v. North Carolina Life & Accident & Health Ins. Guaranty Assn., 455 U.S. 691 (1982) (limited inquiry into jurisdiction when recognizing foreign judgment)
Baker v. General Motors Corp., 522 U.S. 222 (1998) (full faith and credit is exacting; merits not considered)
Fauntleroy v. Lum, 210 U.S. 230 (1908) (jurisdiction vs. merits distinguished in statutory language)
Gonzalez v. Thaler, 565 U.S. 134 (2012) (mandatory prescriptions not always jurisdictional)
Milwaukee County v. M. E. White Co., 296 U.S. 268 (1935) (Full Faith and Credit fosters national unity; judgments integrated)