With Adar v. Smith, the Fifth Circuit Opens a Hole in the Full Faith and Credit Clause

Below is an excerpt of Cassie Hewlings's published work originally appearing in Vol. 86 of the Tulane Law Review. A link to the Tulane Law Review's website is also below.

The Fifth Circuit, sitting en banc, held the obligation imposed on state courts under the Full Faith and Credit Clause does not give rise to a cause of action under § 1983 against nonjudicial state actors; that the Registrar's refusal to issue a birth certificate listing both Adar and Smith as parents did not deny full faith and credit to the New York adoption; and that Louisiana's adoption law restricting joint adoption to married couples was rationally related to its legitimate interest in encouraging stable familial environments for adopted children. Adar v. Smith, 639 F.3d 146, 154, 161-62 (5th Cir. 2011), cert. denied, 132 S. Ct. 400 (2011).

https://www.tulanelawreview.org/pub/volume86/issue6/adar-v-smith

Disclaimer: nothing herein is intended to provide nor should be construed as legal advice; nothing herein creates an attorney-client relationship; and all content herein is that of Cassie Hewlings solely and exclusively in her personal capacity.