Juvenile Court Lacked Jurisdiction to End Parental Rights and Order Adoption

The juvenile court terminated a mother’s parental rights, and ordered that her minor child be adopted by another couple. The court lacked subject-matter jurisdiction to do either thing. The Court of Civil Appeals dismissed the mother’s appeal regarding her parental rights; and it ordered the juvenile court to vacate both orders. R.L. v. J.E.R., No. 2100050 (Ala. Civ. App. Mar. 25, 2011).

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Adoption Without Father’s Consent Was Void

A stepfather adopted his wife’s biological child. Because the child’s father had not consented to the adoption, however, as is required by Alabama statute, the adoption judgment was void. The father’s appeal from that judgment was accordingly dismissed. M.M. v. D.P., No. 2080592 (Ala. Civ. App. Oct. 30, 2009).

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