Recent Development by Cassandra R. Hewlings
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).
About the Author
Cassandra R. Hewlings. J.D. candidate 2013, Tulane University School of Law; B.A. 2008, University of Colorado at Boulder.
Citation
86 Tul. L. Rev. 1359 (2012)