J.G. v. Lauderdale County Department of Human Resources

CourtCourt of Civil Appeals of Alabama
DecidedJanuary 13, 2023
Docket2210455
StatusPublished

This text of J.G. v. Lauderdale County Department of Human Resources (J.G. v. Lauderdale County Department of Human Resources) is published on Counsel Stack Legal Research, covering Court of Civil Appeals of Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
J.G. v. Lauderdale County Department of Human Resources, (Ala. Ct. App. 2023).

Opinion

REL: January 13, 2023

Notice: This opinion is subject to formal revision before publication in the advance sheets of Southern Reporter. Readers are requested to notify the Reporter of Decisions, Alabama Appellate Courts, 300 Dexter Avenue, Montgomery, Alabama 36104-3741 ((334) 229-0650), of any typographical or other errors, in order that corrections may be made before the opinion is published in Southern Reporter.

ALABAMA COURT OF CIVIL APPEALS OCTOBER TERM, 2022-2023

_________________________

2210452, 2210453, 2210454, and 2210455 _________________________

J.G.

v.

Lauderdale County Department of Human Resources

Appeals from Lauderdale Juvenile Court (JU-17-189.04, JU-17-190.05, JU-17-191.06, and JU-17-192.04)

PER CURIAM.

In appeal number 2210452, J.G. ("the father") appeals from a

judgment entered by the Lauderdale Juvenile Court ("the juvenile court")

in case number JU-17-189.04, terminating his parental rights to J.E.G., 2210452, 2210453, 2210454, and 2210455

who was born on March 14, 2006. In appeal number 2210453, the father

appeals from a judgment entered by the juvenile court in case number

JU-17-190.05, terminating his parental rights to E.D.G., who was born

on April 22, 2008. In appeal number 2210454, the father appeals from a

judgment entered by the juvenile court in case number JU-17-191.06,

terminating his parental rights to Y.L.W., who was born on August 28,

2013. In appeal number 2210455, the father appeals from a judgment

entered by the juvenile court in case number JU-17-192.04, terminating

his parental rights to S.R.G., who was born on August 25, 2015. This

court consolidated the father's appeals, ex mero motu. We reverse the

juvenile court's judgments.

Procedural History

On June 21, 2021, the Lauderdale County Department of Human

Resources ("DHR") filed petitions to terminate the parental rights of the

father and of M.G. ("the mother") to J.E.G., E.D.G., Y.L.W., and S.R.G.

("the children"). Following a trial, at which the father was not present,

the juvenile court entered separate judgments on February 18, 2022,

which, apart from each child's name, are otherwise identical and state,

in pertinent part:

2 2210452, 2210453, 2210454, and 2210455

"1. [DHR] failed to meet its burden of proof required to prove [that the children] remain[] dependent; therefore, the court finds the [children are] not dependent and legal care, custody, and control of [the children] is hereby awarded to [the mother].

"2. [DHR's] petition[s] to terminate the parental rights of the mother ... [are] hereby DENIED.

"3. [DHR] is ORDERED to implement a transition plan for [the children] to return home to [the mother] by Friday, February 18, 2022.

"4. It is in the best interest of [the children] to terminate the parental rights of the father[]; therefore, [DHR's] petition[s] to terminate the parental rights of the father ... [are] hereby GRANTED.

"5. The parental rights of the father ... be and the same are hereby permanently severed and terminated as to [the children].

"6. The parties may submit legal briefs within seven (7) days from the date of this order regarding the severance of the father's parental rights in light of the preservation of the mother's parental rights."

On February 28, 2022, the father filed a postjudgment motion in all

four cases, challenging the termination of his parental rights; on that

same date, the juvenile court entered separate orders in each case

denying the father's motion. The father filed a timely notice of appeal in

each case on March 2, 2022.

3 2210452, 2210453, 2210454, and 2210455

Analysis

In Roe v. Conn, 417 F. Supp. 769, 779-80 (M.D. Ala. 1976), the

United States District Court for the Middle District of Alabama

determined that, under the Due Process Clause of the United States

Constitution, U.S. Const., Amend. XIV, § 1, the state can permanently

revoke a parent's fundamental liberty interest only "when the child is

subjected to real physical or emotional harm and less drastic measures

would be unavailing." Id. at 779. Our supreme court eventually

acknowledged that concept of constitutional law by holding that a

juvenile court may terminate parental rights only if it finds " 'that there

exists no viable alternative to the termination of the parent's custodial

rights.' " See Ex parte Ogle, 516 So. 2d 243, 243 (Ala. 1987) (quoting

Hickman v. Alabama Dep't of Pensions & Sec., 489 So. 2d 601, 602 (Ala.

Civ. App. 1986)). In Ex parte Beasley, 564 So. 2d 950 (Ala. 1990), the

Alabama Supreme Court reformulated the language of the test to provide

that a juvenile court "must inquire as to whether 'all viable alternatives

to termination have been considered,' " 564 So. 2d at 952, but we find no

indication that the supreme court meant that a juvenile court satisfies

the Due Process Clause when it only "considers" a viable alternative. As

4 2210452, 2210453, 2210454, and 2210455

the law currently stands, if a court may achieve the compelling

governmental objective at stake through a means other than the drastic

action of permanently revoking the custodial rights of the parent, a

juvenile court cannot terminate parental rights. See J.B. v. DeKalb Cnty.

Dep't of Hum. Res., 12 So. 3d 100, 115 (Ala. Civ. App. 2008) (plurality

opinion) (authored by Moore, J., with Pittman, J., concurring, Thompson,

P.J., concurring in the result, and Bryan and Thomas, JJ., dissenting).

In the judgments in these cases, the juvenile court denied the

petitions to terminate the parental rights of the mother and ordered that

the custody of the children be returned to her. At the same time, the

juvenile court granted the petitions to terminate the parental rights of

the father, who was divorced from the mother and who had only visitation

rights with the children. In his appeals to this court, the father requests

that this court pronounce a bright-line rule to clarify that, based on the

viable-alternative prong of Ex parte Beasley, a juvenile court cannot

terminate the parental rights of a noncustodial parent when the custodial

parent can safely resume custody of the children. We decline to address

that point, however, because it is not necessary to the disposition of these

appeals, which concern solely the issue whether the juvenile court erred

5 2210452, 2210453, 2210454, and 2210455

in terminating the parental rights of this particular noncustodial parent.

The resolution of that issue depends on whether placement of the

children with the mother achieves the state's compelling interest at stake

in the underlying proceedings.

The evidence in the record indicates that the father had been found

indicated for physically abusing S.W., the mother's oldest child and the

father's stepchild, in 2005. See Ala. Admin. Code (Dep't of Hum. Res.), r.

660-5-34-.07(1). The father was found indicated for neglect and abuse of

S.W., J.E.G., and E.D.G.

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Related

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