Code of Alabama
Ala. Code § 26-10A-28 (2026)
Adoption by Other Relatives.
✓ 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THIS SECTION REPEALED BY ACT 2023-92, EFFECTIVE JANUARY 1, 2024.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, §28.)
Notes of Decisions
Cited in 8
cases, 2001–2013 · leading case: O.S. v. E.S., 205 So. 3d 1219 (Ala. Civ. App. 2013).
O.S. v. E.S., 205 So. 3d 1219 (Ala. Civ. App. 2013). “1998) (holding that biological mother had perpetrated a fraud on a court in Georgia, where she had sought a divorce and custody of child previously adopted by grandparents, by making a baseless claim that her consent to the child’s adoption had been obtained by “ ‘undue…”
A.M.B. v. R.B.B., 4 So. 3d 472 (Ala. 2008). “, the court concluded that no pre-placement investigation was necessary, see Ala.Code 1975, § 26-10A-28, and it “grant[ed] custody of [H.”
J.S. v. D.W., 835 So. 2d 174 (Ala. Civ. App. 2001). “pursuant to § 26-10A-28. . D.W. and J.W. were divorced at the time of trial and when the judgment was entered.”
Ellis v. West ex rel. West, 971 So. 2d 20 (Ala. 2007). “Because I recognize that the courts are not the branch of our government charged with the duty of enacting statutory law, 3 I call upon our legislature to consider modifying the exception in § 43-8-48(1) for adoptions by the spouse of a natural parent to include adoptions by…”
Ex Parte Amb, 4 So. 3d 472 (Ala. 2008). “, the court concluded that no pre-placement investigation was necessary, see Ala.Code 1975, § 26-10A-28, and it "grant[ed] custody of [H.”
Ellis v. West Ex Rel. West, 971 So. 2d 20 (Ala. 2007). “Because I recognize that the courts are not the branch of our government charged with the duty of enacting statutory law, [3] I call upon our legislature to consider modifying the exception in § 43-8-48(1) for adoptions by the spouse of a natural parent to include adoptions by…”
Js v. Dw, 835 So. 2d 174 (Ala. Civ. App. 2001). “pursuant to § 26-10A-28. [2] D.W. and J.W. were divorced at the time of trial and when the judgment was entered.”
In Re Matter of the Adoption of F.I.T., 43 So. 3d 621 (Ala. Civ. App. 2010). “§ 26-10A-28, Ala.Code 1975. It is not clear whether, in this case, the probate court waived the requirement for a pre-placement investigation of the petitioners.”
Ala. Code § 26-10A-28(l): 1 case
O.S. v. E.S., 205 So. 3d 1219 (Ala. Civ. App. 2013). “1998) (holding that biological mother had perpetrated a fraud on a court in Georgia, where she had sought a divorce and custody of child previously adopted by grandparents, by making a baseless claim that her consent to the child’s adoption had been obtained by “ ‘undue…”
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