Code of Alabama
Ala. Code § 26-10A-11 (2026)
Consent or Relinquishment.
✓ official Alabama Legislature (ALISON) text, laws through the 2026 Regular Session
THIS SECTION REPEALED BY ACT 2023-92, EFFECTIVE JANUARY 1, 2024.
(Acts 1990, No. 90-554, p. 912, §11; Acts 98-101, p. 118, §1.)
Notes of Decisions
Cited in 17
cases, 1999–2017 · leading case: Hays v. Hays, 946 So. 2d 867 (Ala. Civ. App. 2006).
Hays v. Hays, 946 So. 2d 867 (Ala. Civ. App. 2006). “Thereafter, a more direct examination of § 26-10A-11 and particularly § 26-10A-11(b), Ala.”
C.V. v. J.M.J., 810 So. 2d 700 (Ala. 2001). “Thus, I believe his conduct acted as more than implied consent to adoption under § 26-10A-11; I believe it constituted abandonment as that term is defined in the 1984 Child Protection Act, § 26-18-1 et seq.”
M.D.C. v. K.D., 39 So. 3d 1117 (Ala. 2009). “, provides that a parent who consents to the adoption of his or her child forfeits ‘all rights and obligations,’ Ala.Code 1975, § 26-10A-11(a)(6) (emphasis added), and that ‘[u]pon a final decree of adoption, the natural parents of the adoptee, except for a natural parent who is…”
E.W.H. v. A.M.P., 997 So. 2d 1008 (Ala. 2008). “When a consent or relinquishment is required, §§ 26-10A-11 and -12 prescribe the requirements necessary for an express, written consent or relinquishment (and provide a form therefor), while § 26-10A-9 sets out the acts or omissions by which a consent or relinquishment required…”
S.C.W. v. C.B., 826 So. 2d 844 (Ala. 2001). “ts of the adoptee and there is a finding that the agency *856 has unreasonably withheld its consent; and “(5) The putative father if made known by the mother or is otherwise made known to the court provided he responds within 30 days to the notice he receives under Section…”
Alabama Dep't of Human Resources v. B.V., 59 So. 3d 700 (Ala. Civ. App. 2010). “See § 26-10A-11(b) (“When the person sought to be adopted is an adult, .”
Ex Parte CV, 810 So. 2d 700 (Ala. 2001). “Thus, I believe his conduct acted as more than implied consent to adoption under § 26-10A-11; I believe it constituted abandonment as that term is defined in the 1984 Child Protection Act, § 26-18-1 et seq.”
B.F. v. L.J., 771 So. 2d 1029 (Ala. Civ. App. 1999). “Consent to an adoption, if express, must be in writing, § 26-10A-11; however, § 26-10A-9 recognizes implied consent.”
I.B. v. T.N., 194 So. 3d 221 (Ala. Civ. App. 2015). “When a consent or relinquishment is required, §§ 26-10A-11 and-12[, Ala.Code 1975,] prescribe the requirements necessary for an express, written consent or relinquishment (and provide a form therefor), while § 26-10A-9[, Ala.”
Ex parte MDC, 39 So. 3d 1117 (Ala. 2009). “, provides that a parent who consents to the adoption of his or her child forfeits `all rights and obligations,' Ala.Code 1975, § 26-10A-11(a)(6) (emphasis added), and that `[u]pon a final decree of adoption, the natural parents of the adoptee, except for a natural parent who is…”
Fp v. Jkm, 857 So. 2d 110 (Ala. Civ. App. 2001). “Justice See's special concurrence states, in part: "It is clear that a parent can expressly consent to the adoption of his or her child before the child's birth, see Ala.Code 1975, §§ 26-10A-11(2), 26-10A-13(a) *122 and (b).”
Ex Parte FP, 857 So. 2d 125 (Ala. 2003). “Justice See's special concurrence states, in part: "`It is clear that a parent can expressly consent to the adoption of his or her child before the child's birth, see Ala.Code 1975, §§ 26-10A-11(2), 26-10A-13(a) and (b).”
Ala. Code § 26-10A-11(2): 4 cases
C.V. v. J.M.J., 810 So. 2d 700 (Ala. 2001). “Thus, I believe his conduct acted as more than implied consent to adoption under § 26-10A-11; I believe it constituted abandonment as that term is defined in the 1984 Child Protection Act, § 26-18-1 et seq.”
Ex Parte CV, 810 So. 2d 700 (Ala. 2001). “Thus, I believe his conduct acted as more than implied consent to adoption under § 26-10A-11; I believe it constituted abandonment as that term is defined in the 1984 Child Protection Act, § 26-18-1 et seq.”
Fp v. Jkm, 857 So. 2d 110 (Ala. Civ. App. 2001). “Justice See's special concurrence states, in part: "It is clear that a parent can expressly consent to the adoption of his or her child before the child's birth, see Ala.Code 1975, §§ 26-10A-11(2), 26-10A-13(a) *122 and (b).”
Ex Parte FP, 857 So. 2d 125 (Ala. 2003). “Justice See's special concurrence states, in part: "`It is clear that a parent can expressly consent to the adoption of his or her child before the child's birth, see Ala.Code 1975, §§ 26-10A-11(2), 26-10A-13(a) and (b).”
Ala. Code § 26-10A-11(a): 2 cases
Hays v. Hays, 946 So. 2d 867 (Ala. Civ. App. 2006). “Thereafter, a more direct examination of § 26-10A-11 and particularly § 26-10A-11(b), Ala.”
M.M. v. K.H., 257 So. 3d 292 (Ala. Civ. App. 2017).
Ala. Code § 26-10A-11(a)(6): 3 cases
M.D.C. v. K.D., 39 So. 3d 1117 (Ala. 2009). “, provides that a parent who consents to the adoption of his or her child forfeits ‘all rights and obligations,’ Ala.Code 1975, § 26-10A-11(a)(6) (emphasis added), and that ‘[u]pon a final decree of adoption, the natural parents of the adoptee, except for a natural parent who is…”
Ex parte MDC, 39 So. 3d 1117 (Ala. 2009). “, provides that a parent who consents to the adoption of his or her child forfeits `all rights and obligations,' Ala.Code 1975, § 26-10A-11(a)(6) (emphasis added), and that `[u]pon a final decree of adoption, the natural parents of the adoptee, except for a natural parent who is…”
MDC v. Kd, 39 So. 3d 1105 (Ala. Civ. App. 2008).
Ala. Code § 26-10A-11(b): 2 cases
Hays v. Hays, 946 So. 2d 867 (Ala. Civ. App. 2006). “Thereafter, a more direct examination of § 26-10A-11 and particularly § 26-10A-11(b), Ala.”
Alabama Dep't of Human Resources v. B.V., 59 So. 3d 700 (Ala. Civ. App. 2010). “See § 26-10A-11(b) (“When the person sought to be adopted is an adult, .”
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