After a long history of secrecy in domestic adoption in the United States, there is a robust trend toward openness. That is, however, not the case with international adoption.

Part II of this Article will examine the doctrine of international comity, traditionally thought to give courts the power to recognize foreign decrees, as it applies to international adoption. First, the ability of courts to recognize foreign decrees of "status" generally will be discussed. Next, the focus will be on courts' authority to recognize the parent-child status created by foreign adoptions. This subpart will also review treaties and statutes that touch on the recognition of foreign adoption decrees. Part III will consider a traditional limitation on comity-that courts need not accept judgments that are "repugnant" or against the public policy of the state-as it applies to international adoption. The Article concludes that courts find "repugnant" those international adoptions that fail to mimic American notions of a nuclear family. Finally, Part IV will suggest a child-centered approach to replace the "repugnance" limitation on international comity.

Part I of this article discusses the profiles of batterers and victims as a predicate for analyzing applications of the spousal immunity privilege in Texas. Part II briefly explores the origin and nature of the spousal privileges. Part III examines the history of the spousal privilege and spousal crime exception in Texas, and the recent statutory change. Part IV discusses the application of similar exceptions in other states. Part V briefly explores the application of the spousal crime exception to the communications privilege. Finally, Part VI suggests how Texas courts should properly apply this new rule of evidence in domestic violence cases.

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