Ex parte E.L. (In re E.L. v. V.L.)

Summary

The court held that Alabama was not required to recognize or enforce the Georgia adoption decree because the Georgia court lacked subject-matter jurisdiction to grant an adoption that did not terminate the existing parent's parental rights. The court distinguished a jurisdictional defect from an error on the merits and concluded that the decree was void under the applicable Georgia adoption statutes. Justice Parker concurred specially regarding the statutory nature of adoption, while Justice Shaw dissented, reasoning that any defect concerned the merits rather than jurisdiction.