Ledoux-Nottingham v. DownsAnnotate this Case
Mother and Father were divorced in Colorado. After Father died, Mother and her two minor children moved to Florida. Grandparents subsequently initiated a proceeding in Colorado seeking visitation with the children. Mother filed a separate action in Florida to register the Colorado judgment dissolving her marriage and for a judicial determination that Grandparents had no legal right to timesharing with her children. Colorado then issued a judgment awarding Grandparents visitation with the children (the Colorado order). Thereafter, the Florida court entered a final order registering and domesticating the Colorado order. Mother appealed, arguing that the Colorado order was unenforceable as a matter of Florida law and public policy because it violated “childrearing autonomy.” The court of appeal concluded that the Colorado order was entitled to full faith and credit. The Supreme Court affirmed, holding that Florida was required to enforce the Colorado order despite the fact that entry of a similar judgment by a Florida court under the circumstances presented here would be prohibited by the Florida Constitution.