Volume 86

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

[T]he 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).

The Louisiana Supreme Court Affirms Health Care Providers' Freedom To Contract for Below-Schedule Reimbursement Rates in Agilus Health v. Accor Lodging North America

The Louisiana Supreme Court held that valid PPO contracts did not violate Louisiana law by authorizing reimbursement payments to providers in amounts less than those specified by the LWCA's reimbursement schedule. Agilus Health v. Accor Lodging North America, 2010-0800, pp.11-12 (La. 11/30/10); 52 So. 3d 68, 76-77.