Code of Alabama
Ala. Code § 12-15-320 (2026)
Dispositions.
✓ official Alabama Legislature (ALISON) text, current July 2026
(a) Termination of parental rights cases shall be given priority over other cases. The trial on the petition for termination of parental rights shall be completed within 90 days after service of process has been perfected. The trial court judge shall enter a final order within 30 days of the completion of the trial.
(b) If the juvenile court determines that the parents of a child are unwilling or unable to act as parents and terminates their parental rights, it may do the following:
(1) Transfer or continue the permanent legal custody of the child to the Department of Human Resources or to any public or private licensed child-placing agency able and willing to assume the care and maintenance of the child. An order of the juvenile court which terminates parental rights and awards permanent legal custody to the Department of Human Resources or to a licensed child-placing agency shall mean that the Department of Human Resources or the licensed child-placing agency shall have authority to make permanent plans for the child, including the authority to place for adoption and consent to adoption.
(2) Transfer or continue the permanent legal custody of the child to the petitioner who, after study by the Department of Human Resources, is found to be able to properly receive and care for the child.
(Acts 1984, No. 84-261, p. 442, §8; §26-18-8; amended and renumbered by Act 2008-277, p. 441, §19; Act 2013-157, p. 297, §2.)
Notes of Decisions
Cited in 31
cases (13 in the last 5 years), 2013–2025 · leading case: Montgomery Cnty. Dep't of Human Resources v. T.S., 218 So. 3d 1252 (Ala. Civ. App. 2016).
Montgomery Cnty. Dep't of Human Resources v. T.S., 218 So. 3d 1252 (Ala. Civ. App. 2016). “In addition to the deadline for conducting a trial noted earlier, § 12-15-320(a) also requires that “[t]he trial court judge shall enter a final order within 30 days of the completion of the trial.”
M.H. v. Cleburne Cnty. Dep't of Human Resources, 158 So. 3d 471 (Ala. Civ. App. 2014). “Initially, we address the mother’s correct assertion that the juvenile court failed to enter its judgments in compliance with § 12-15-320(a), Ala.Code 1975 (requiring the entry of a final judgment within 30 days of the completion of a trial), and Rule 25(D), Ala.”
C.F. v. State Dep't of Human Resources, 218 So. 3d 1246 (Ala. Civ. App. 2016). “DHR served the mother with the petition, and, pursuant to Ala.Code 1975, § 12-15-320(a), the juvenile court set the trial for January 28, 2016.”
J.L. v. Morgan Cnty. Dep't of Human Resources, 182 So. 3d 570 (Ala. Civ. App. 2015). “The mother’s sole issue on appeal is whether the juvenile court’s admitted failure to comply with certain requirements of § 12-15-320(a), Ala.Code 1975, renders the judgments void for lack of jurisdiction.”
Ex parte Alabama Dep't of Human Resources, 154 So. 3d 1060 (Ala. Civ. App. 2014). “” In other words, the purpose of a permanency hearing under § 12-15-321 is not to determine the appropriate permanent placement of the child, but to ensure that “the Department of Human Resources” is using reasonable efforts to achieve the permanency plan it has formulated for…”
S.H. v. Macon Cnty. Dep't of Human Resources, 195 So. 3d 311 (Ala. Civ. App. 2015). “In interpreting § 12-15-320(b), this court stated: “Based on [the language of § 12-15-320(b)], once the parental rights of a child’s parents are terminated, a juvenile court may either place the child in the permanent legal custody of ‘the Department of Human Resources,’ another…”
Marshall Cnty. Dep't of Human Resources v. M.B., 176 So. 3d 217 (Ala. Civ. App. 2015). “02 cases to alter, amend, or vacate the judgments, asserting that the juvenile court’s judgments were not in compliance with Ala.Code 1975, § 12-15-320, and were contrary to this court’s decision in Ex parte Alabama Department of Human Resources, 154 So.”
Montgomery Cnty. Dep't of Human Resources v. A.S.N., 206 So. 3d 661 (Ala. Civ. App. 2016). “The juvenile court did not comply with § 12-15-320(a), which requires that a judgment in a termination-of-parental-rights action be entered within 30 days of the completion of trial.”
C.P.M. v. Shelby Cnty. Dep't of Human Resources, 185 So. 3d 461 (Ala. Civ. App. 2015). “” In addition, § 12-15-320(a), Ala.Code 1975, requires a juvenile court to enter a final judgment within 30 days of the completion of a trial in a case involving the termination of parental rights.”
A.D.W. v. Shelby Cnty. Dep't of Human Resources, 192 So. 3d 405 (Ala. Civ. App. 2015). “We note that the juvenile court, in entering its July 6, 2015, order, stated that it was entering that order in compliance with the time limitations for termination actions set forth-in § 12-15-320(a), Ala.Code 1975, and that the mother had had six months since the service 'of…”
C.C. v. L.J., 176 So. 3d 183 (Ala. Civ. App. 2013). “ion to be ordered in particular circumstances by the juvenile court (§ 12-15-318), (b) that termination of parental rights may be ordered by the juvenile court upon a proper showing of grounds therefor (§ 12-15-319), and (c) that additional actions are authorized to be…”
Montgomery Cnty. Dep't of Human Resources v. N.B., 196 So. 3d 1205 (Ala. Civ. App. 2015). “” We further note that § 12-15-320(a), Ala. Code 1975, provides that, in termination-of-parental-rights cases,, “[t]he trial court judge shall enter a final order within 30 days of the completion of the trial.”
— Ala. Code § 12-15-320(a) — 12 cases
Montgomery Cnty. Dep't of Human Resources v. T.S., 218 So. 3d 1252 (Ala. Civ. App. 2016). “In addition to the deadline for conducting a trial noted earlier, § 12-15-320(a) also requires that “[t]he trial court judge shall enter a final order within 30 days of the completion of the trial.”
M.H. v. Cleburne Cnty. Dep't of Human Resources, 158 So. 3d 471 (Ala. Civ. App. 2014). “Initially, we address the mother’s correct assertion that the juvenile court failed to enter its judgments in compliance with § 12-15-320(a), Ala.Code 1975 (requiring the entry of a final judgment within 30 days of the completion of a trial), and Rule 25(D), Ala.”
C.F. v. State Dep't of Human Resources, 218 So. 3d 1246 (Ala. Civ. App. 2016). “DHR served the mother with the petition, and, pursuant to Ala.Code 1975, § 12-15-320(a), the juvenile court set the trial for January 28, 2016.”
J.L. v. Morgan Cnty. Dep't of Human Resources, 182 So. 3d 570 (Ala. Civ. App. 2015). “The mother’s sole issue on appeal is whether the juvenile court’s admitted failure to comply with certain requirements of § 12-15-320(a), Ala.Code 1975, renders the judgments void for lack of jurisdiction.”
Montgomery Cnty. Dep't of Human Resources v. A.S.N., 206 So. 3d 661 (Ala. Civ. App. 2016). “The juvenile court did not comply with § 12-15-320(a), which requires that a judgment in a termination-of-parental-rights action be entered within 30 days of the completion of trial.”
— Ala. Code § 12-15-320(b) — 9 cases
S.H. v. Macon Cnty. Dep't of Human Resources, 195 So. 3d 311 (Ala. Civ. App. 2015). “In interpreting § 12-15-320(b), this court stated: “Based on [the language of § 12-15-320(b)], once the parental rights of a child’s parents are terminated, a juvenile court may either place the child in the permanent legal custody of ‘the Department of Human Resources,’ another…”
Ex parte Alabama Dep't of Human Resources, 154 So. 3d 1060 (Ala. Civ. App. 2014). “” In other words, the purpose of a permanency hearing under § 12-15-321 is not to determine the appropriate permanent placement of the child, but to ensure that “the Department of Human Resources” is using reasonable efforts to achieve the permanency plan it has formulated for…”
Marshall Cnty. Dep't of Human Resources v. M.B., 176 So. 3d 217 (Ala. Civ. App. 2015). “02 cases to alter, amend, or vacate the judgments, asserting that the juvenile court’s judgments were not in compliance with Ala.Code 1975, § 12-15-320, and were contrary to this court’s decision in Ex parte Alabama Department of Human Resources, 154 So.”
Ex parte Limestone Cnty. Dep't of Human Res., 255 So. 3d 210 (Ala. Civ. App. 2017).
C.B.W. v. R.H. & J.H. (Appeal from Baldwin Juv. Court: JU-18-952.03). (Ala. Civ. App. 2025).
— Ala. Code § 12-15-320(b)(1) — 6 cases
Ex parte Alabama Dep't of Human Resources, 154 So. 3d 1060 (Ala. Civ. App. 2014). “” In other words, the purpose of a permanency hearing under § 12-15-321 is not to determine the appropriate permanent placement of the child, but to ensure that “the Department of Human Resources” is using reasonable efforts to achieve the permanency plan it has formulated for…”
Ex parte Limestone Cnty. Dep't of Human Res., 255 So. 3d 210 (Ala. Civ. App. 2017).
R.N. v. J.B. & K.B. (Appeal from Madison Juv. Court: JU-21-454.02). (Ala. Civ. App. 2024).
O.W. v. J.B. & K.B. (Appeal from Madison Juv. Court: JU-21-454.02). (Ala. Civ. App. 2024).
Madison Cnty. Dep't of Human Resources v. J.B. & K.B. (Appeal from Madison Juv. Court: JU-21-454.02). (Ala. Civ. App. 2024).
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