Code of Alabama
Ala. Code § 26-10A-13 (2026)
Time of Consent or Relinquishment; Filing with Court.
✓ official Alabama Legislature (ALISON) text, current July 2026
THIS SECTION REPEALED BY ACT 2023-92, EFFECTIVE JANUARY 1, 2024.
(Acts 1990, No. 90-554, p. 912, §13.)
Notes of Decisions
Cited in 14
cases (2 in the last 5 years), 1994–2024 · leading case: A.E.C. v. J.R.M., 46 So. 3d 481 (Ala. Civ. App. 2009).
A.E.C. v. J.R.M., 46 So. 3d 481 (Ala. Civ. App. 2009). “Code 1975, as applied in this case, deprived the birth mother of her constitutional due-process rights under the Fourteenth Amendment to the United States Constitution because, she said, the consent-for-adoption form she signed failed to give notice of all the withdrawal…”
K.L.R. v. K.G.S., 264 So. 3d 65 (Ala. Civ. App. 2018). “These sections and the proceedings which occur after a birth do not concern the requirements under § 26-10A-13 for execution and delivery of the withdrawal of consent document that [the birth mother] received and understood.”
C.V. v. J.M.J., 810 So. 2d 700 (Ala. 2001). “had impliedly consented to the adoption of his son, § 26-10A-13, Ala.Code 1975, provides that an express consent to adoption can be withdrawn: “(a) A consent or relinquishment may be taken at any time, except that once signed or confirmed, may be withdrawn within five days after…”
F.P. v. J.K.M., 857 So. 2d 125 (Ala. 2003). “, § 26-10A-13, Ala.Code 1975, provides that an express consent can be withdrawn: [stating certain means for withdrawing it].”
E.W.H. v. A.M.P., 997 So. 2d 1008 (Ala. 2008). “See § 26-10A-13(c), concerning written consents, which states that “[a]ll consents or relinquishments required by this act shall be filed with the court in which the petition for adoption is pending before the final decree of adoption is entered,” and § 26-10A~24(a)(3), which…”
F.P. v. J.K.M., 857 So. 2d 110 (Ala. Civ. App. 2001). “, § 26-10A-13, Ala.Code 1975, provides that an express consent can be withdrawn: [stating certain means for withdrawing it].”
H.S. v. G.H., 640 So. 2d 959 (Ala. Civ. App. 1994). “Code 1975, § 26-10A-13, provides in pertinent part: “(a) A consent or relinquishment .”
K.L.R. v. K.G.S., 264 So. 3d 65 (Ala. Civ. App. 2018). “These sections and the proceedings which occur after a birth do not concern the requirements under § 26-10A-13 for execution and delivery of the withdrawal of consent document that [the birth mother] received and understood.”
T.E.B. & D.K.G. v. C.A. (Appeal from Montgomery Prob. Court: 2022-A0019). (Ala. Civ. App. 2024). “Code 1975, [former] § 26-10A-13 (providing that a consent executed by parent may be withdrawn within five days of the birth of the child or the execution of the consent, whichever comes last, and that a consent executed by a parent may be withdrawn within 14 days of the birth of…”
Ex Parte CV, 810 So. 2d 700 (Ala. 2001). “had impliedly consented to the adoption of his son, § 26-10A-13, Ala.Code 1975, provides that an express consent to adoption can be withdrawn: "(a) A consent or relinquishment may be taken at any time, except that once signed or confirmed, may be withdrawn within five days after…”
Fp v. Jkm, 857 So. 2d 110 (Ala. Civ. App. 2001). “, § 26-10A-13, Ala.Code 1975, provides that an express consent can be withdrawn: [stating certain means for withdrawing it].”
Ex Parte FP, 857 So. 2d 125 (Ala. 2003). “, § 26-10A-13, Ala.Code 1975, provides that an express consent can be withdrawn: [stating certain means for withdrawing it].”
— Ala. Code § 26-10A-13(a) — 4 cases
K.L.R. v. K.G.S., 264 So. 3d 65 (Ala. Civ. App. 2018). “These sections and the proceedings which occur after a birth do not concern the requirements under § 26-10A-13 for execution and delivery of the withdrawal of consent document that [the birth mother] received and understood.”
A.E.C. v. J.R.M., 46 So. 3d 481 (Ala. Civ. App. 2009). “Code 1975, as applied in this case, deprived the birth mother of her constitutional due-process rights under the Fourteenth Amendment to the United States Constitution because, she said, the consent-for-adoption form she signed failed to give notice of all the withdrawal…”
K.L.R. v. K.G.S., 264 So. 3d 65 (Ala. Civ. App. 2018). “These sections and the proceedings which occur after a birth do not concern the requirements under § 26-10A-13 for execution and delivery of the withdrawal of consent document that [the birth mother] received and understood.”
T.E.B. & D.K.G. v. C.A. (Appeal from Montgomery Prob. Court: 2022-A0019). (Ala. Civ. App. 2024). “Code 1975, [former] § 26-10A-13 (providing that a consent executed by parent may be withdrawn within five days of the birth of the child or the execution of the consent, whichever comes last, and that a consent executed by a parent may be withdrawn within 14 days of the birth of…”
— Ala. Code § 26-10A-13(b) — 2 cases
A.E.C. v. J.R.M., 46 So. 3d 481 (Ala. Civ. App. 2009). “Code 1975, as applied in this case, deprived the birth mother of her constitutional due-process rights under the Fourteenth Amendment to the United States Constitution because, she said, the consent-for-adoption form she signed failed to give notice of all the withdrawal…”
T.E.B. & D.K.G. v. C.A. (Appeal from Montgomery Prob. Court: 2022-A0019). (Ala. Civ. App. 2024). “Code 1975, [former] § 26-10A-13 (providing that a consent executed by parent may be withdrawn within five days of the birth of the child or the execution of the consent, whichever comes last, and that a consent executed by a parent may be withdrawn within 14 days of the birth of…”
— Ala. Code § 26-10A-13(c) — 3 cases
E.W.H. v. A.M.P., 997 So. 2d 1008 (Ala. 2008). “See § 26-10A-13(c), concerning written consents, which states that “[a]ll consents or relinquishments required by this act shall be filed with the court in which the petition for adoption is pending before the final decree of adoption is entered,” and § 26-10A~24(a)(3), which…”
D.F.H. v. E.R.S. (Ala. Civ. App. 2023).
Ex Parte AMP, 997 So. 2d 1008 (Ala. 2008).
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