Code of Alabama
Ala. Code § 26-10A-14 (2026)
Withdrawal of Consent or Relinquishment.
✓ 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THIS SECTION REPEALED BY ACT 2023-92, EFFECTIVE JANUARY 1, 2024.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, §14; Act 2002-417, p. 1061, §1.)
Notes of Decisions
Cited in 10
cases (1 in the last 5 years), 1994–2024 · leading case: K.L.R. v. K.G.S., 264 So. 3d 65 (Ala. Civ. App. 2018).
K.L.R. v. K.G.S., 264 So. 3d 65 (Ala. Civ. App. 2018). “Although a party must appeal within 14 days from a final decree of adoption or an order upon a petition to withdraw consent to an adoption pursuant to Ala. Code 1975, § 26-10A-14 and § 26-10A-26, respectively, the protective order does not address any of the issues disposed of…”
O.S. v. E.S., 205 So. 3d 1219 (Ala. Civ. App. 2013). “Even assuming that filing the independent action in the circuit court rather than in the court issuing the order being challenged was authorized under Rule 60(b), the invocation of equitable jurisdiction would not permit the limitations period of § 26-10A-14 to be circumvented…”
A.E.C. v. J.R.M., 46 So. 3d 481 (Ala. Civ. App. 2009). “Code 1975, sets forth the time limitations for withdrawing a signed consent-for-adoption form, as follows: “a) The consent or relinquishment, once signed or confirmed, may not be withdrawn except: “(1) As provided in Section 26-10A-13; or “(2) At any time until the final decree…”
O.S. v. E.S., 205 So. 3d 1233 (Ala. 2014). “Code 1975, specifically, § 26-10A-14(a), Ala.Code 1975, which provides, in pertinent part: “ ‘(a) The consent [to an adoption] .”
H.S. v. G.H., 640 So. 2d 959 (Ala. Civ. App. 1994). “Code 1975, § 26-10A-14(a), provides in pertinent part: “(a) The consent or relinquishment, once signed or confirmed, may not be withdrawn except: “(1) As provided in Section 26-10A-13; or “(2) At any time until the final decree upon a showing that the consent or relinquishment…”
K.L.B. v. W.M.F., 864 So. 2d 333 (Ala. Civ. App. 2002). “See § 26-10A-14, Ala.Code 1975. Fashioning a statutory rule or mechanism for withdrawing an implied consent would be much more problematic, however.”
K.L.R. v. K.G.S., 264 So. 3d 65 (Ala. Civ. App. 2018). “Although a party must appeal within 14 days from a final decree of adoption or an order upon a petition to withdraw consent to an adoption pursuant to Ala. Code 1975, § 26-10A-14 and § 26-10A-26, respectively, the protective order does not address any of the issues disposed of…”
A.M.H. v. T.L.H., 733 So. 2d 421 (Ala. Civ. App. 1998). “§ 26-10A-14(a)(2), [Ala.Code 1975]. Said adoption consent herein was not obtained by undue influence, fraud or deceit by [the adoptive parents] or any agent for either of them, and [A.”
Klb v. Wmf, 864 So. 2d 333 (Ala. Civ. App. 2002). “See § 26-10A-14, Ala.Code 1975. Fashioning a statutory rule or mechanism for withdrawing an implied consent would be much more problematic, however.”
T.E.B. & D.K.G. v. C.A. (Appeal from Montgomery Prob. Court: 2022-A0019). (Ala. Civ. App. 2024). “3d at 655 , and not the resolution of a petition to withdraw consent under former § 26-10A-14, the same result obtains in the present case.”
— Ala. Code § 26-10A-14(2) — 1 case
O.S. v. E.S., 205 So. 3d 1219 (Ala. Civ. App. 2013). “Even assuming that filing the independent action in the circuit court rather than in the court issuing the order being challenged was authorized under Rule 60(b), the invocation of equitable jurisdiction would not permit the limitations period of § 26-10A-14 to be circumvented…”
— Ala. Code § 26-10A-14(a) — 5 cases
O.S. v. E.S., 205 So. 3d 1233 (Ala. 2014). “Code 1975, specifically, § 26-10A-14(a), Ala.Code 1975, which provides, in pertinent part: “ ‘(a) The consent [to an adoption] .”
O.S. v. E.S., 205 So. 3d 1219 (Ala. Civ. App. 2013). “Even assuming that filing the independent action in the circuit court rather than in the court issuing the order being challenged was authorized under Rule 60(b), the invocation of equitable jurisdiction would not permit the limitations period of § 26-10A-14 to be circumvented…”
K.L.R. v. K.G.S., 264 So. 3d 65 (Ala. Civ. App. 2018). “Although a party must appeal within 14 days from a final decree of adoption or an order upon a petition to withdraw consent to an adoption pursuant to Ala. Code 1975, § 26-10A-14 and § 26-10A-26, respectively, the protective order does not address any of the issues disposed of…”
H.S. v. G.H., 640 So. 2d 959 (Ala. Civ. App. 1994). “Code 1975, § 26-10A-14(a), provides in pertinent part: “(a) The consent or relinquishment, once signed or confirmed, may not be withdrawn except: “(1) As provided in Section 26-10A-13; or “(2) At any time until the final decree upon a showing that the consent or relinquishment…”
K.L.R. v. K.G.S., 264 So. 3d 65 (Ala. Civ. App. 2018). “Although a party must appeal within 14 days from a final decree of adoption or an order upon a petition to withdraw consent to an adoption pursuant to Ala. Code 1975, § 26-10A-14 and § 26-10A-26, respectively, the protective order does not address any of the issues disposed of…”
— Ala. Code § 26-10A-14(a)(2) — 5 cases
K.L.R. v. K.G.S., 264 So. 3d 65 (Ala. Civ. App. 2018). “Although a party must appeal within 14 days from a final decree of adoption or an order upon a petition to withdraw consent to an adoption pursuant to Ala. Code 1975, § 26-10A-14 and § 26-10A-26, respectively, the protective order does not address any of the issues disposed of…”
A.E.C. v. J.R.M., 46 So. 3d 481 (Ala. Civ. App. 2009). “Code 1975, sets forth the time limitations for withdrawing a signed consent-for-adoption form, as follows: “a) The consent or relinquishment, once signed or confirmed, may not be withdrawn except: “(1) As provided in Section 26-10A-13; or “(2) At any time until the final decree…”
H.S. v. G.H., 640 So. 2d 959 (Ala. Civ. App. 1994). “Code 1975, § 26-10A-14(a), provides in pertinent part: “(a) The consent or relinquishment, once signed or confirmed, may not be withdrawn except: “(1) As provided in Section 26-10A-13; or “(2) At any time until the final decree upon a showing that the consent or relinquishment…”
K.L.R. v. K.G.S., 264 So. 3d 65 (Ala. Civ. App. 2018). “Although a party must appeal within 14 days from a final decree of adoption or an order upon a petition to withdraw consent to an adoption pursuant to Ala. Code 1975, § 26-10A-14 and § 26-10A-26, respectively, the protective order does not address any of the issues disposed of…”
A.M.H. v. T.L.H., 733 So. 2d 421 (Ala. Civ. App. 1998). “§ 26-10A-14(a)(2), [Ala.Code 1975]. Said adoption consent herein was not obtained by undue influence, fraud or deceit by [the adoptive parents] or any agent for either of them, and [A.”
— Ala. Code § 26-10A-14(c) — 1 case
A.E.C. v. J.R.M., 46 So. 3d 481 (Ala. Civ. App. 2009). “Code 1975, sets forth the time limitations for withdrawing a signed consent-for-adoption form, as follows: “a) The consent or relinquishment, once signed or confirmed, may not be withdrawn except: “(1) As provided in Section 26-10A-13; or “(2) At any time until the final decree…”
— Ala. Code § 26-10A-14(e) — 3 cases
K.L.R. v. K.G.S., 264 So. 3d 65 (Ala. Civ. App. 2018). “Although a party must appeal within 14 days from a final decree of adoption or an order upon a petition to withdraw consent to an adoption pursuant to Ala. Code 1975, § 26-10A-14 and § 26-10A-26, respectively, the protective order does not address any of the issues disposed of…”
T.E.B. & D.K.G. v. C.A. (Appeal from Montgomery Prob. Court: 2022-A0019). (Ala. Civ. App. 2024). “3d at 655 , and not the resolution of a petition to withdraw consent under former § 26-10A-14, the same result obtains in the present case.”
K.L.R. v. K.G.S., 264 So. 3d 65 (Ala. Civ. App. 2018). “Although a party must appeal within 14 days from a final decree of adoption or an order upon a petition to withdraw consent to an adoption pursuant to Ala. Code 1975, § 26-10A-14 and § 26-10A-26, respectively, the protective order does not address any of the issues disposed of…”
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