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

V.L. and E.L., a same-sex couple, raised three children conceived via assisted reproduction; E.L. is the biological mother.
V.L. petitioned for and obtained a Georgia Superior Court final adoption decree naming her as a legal parent while E.L. retained her parental rights.
The couple later separated while living in Alabama; V.L. sought registration of the Georgia adoption in Alabama and visitation/custody relief.
Alabama family court awarded V.L. visitation; the Alabama Court of Civil Appeals remanded for an evidentiary hearing.
The Alabama Supreme Court reversed, holding the Georgia adoption judgment was not entitled to full faith and credit because, it concluded, the Georgia court lacked subject-matter jurisdiction under Georgia law (Ga. Code §19-8-5(a)).
The U.S. Supreme Court granted certiorari and reversed the Alabama Supreme Court, holding the Georgia judgment was presumptively valid and must be given full faith and credit unless jurisdiction is disproven.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Alabama must give Full Faith and Credit to Georgia adoption judgment	V.L.: Georgia decree is a final judgment from a court with adjudicatory authority and must be recognized	E.L.: Georgia court lacked subject-matter jurisdiction under GA law (§19-8-5(a)), so Alabama need not recognize it	Court: Full Faith and Credit applies; Georgia court had jurisdiction over adoption matters and jurisdiction is presumed unless rebutted
Whether GA statutory requirement that natural parents surrender rights is jurisdictional	V.L.: §19-8-5(a) is a merits/rule-of-decision requirement, not jurisdictional	E.L.: The provision is mandatory and therefore deprives court of jurisdiction to enter adoption while natural parent remains	Court: §19-8-5(a) does not speak in jurisdictional terms; mandatory statute does not automatically make subject-matter jurisdictional; Alabama erred in treating it as jurisdictional

Milwaukee County v. M.E. White Co., 296 U.S. 268 (explaining Full Faith and Credit integrates state judgments nationally)
Milliken v. Meyer, 311 U.S. 457 (presumption of jurisdiction for courts of general jurisdiction)
Adam v. Saenger, 303 U.S. 59 (jurisdiction presumed from record of court of general jurisdiction)
Baker v. General Motors Corp., 522 U.S. 222 (final judgment qualifies for recognition if court had adjudicatory authority)
Underwriters Nat. Assurance Co. v. North Carolina Life & Accident & Health Ins. Guaranty Assn., 455 U.S. 691 (courts may inquire into foreign court's jurisdictional basis but inquiry is limited)
Fauntleroy v. Lum, 210 U.S. 230 (interpret ambiguous statutory language cautiously when jurisdiction is implicated)
Gonzalez v. Thaler, 565 U.S. 134 (mandatory statutory language is not automatically jurisdictional)