C.C. v. L.J., 176 So. 3d 208

Mother initiated in July 2012 a civil action to establish paternity and terminate the father's parental rights; father initially appeared pro se but later appeared through counsel.
A March 2013 ore tenus judgment terminated the father's parental rights based on grounds including abandonment and failure to provide; paternity had already been established in September 2012.
The juvenile court found the father abandoned the child, failed to provide for material needs, had little contact, and had not attempted to adjust his circumstances post-birth.
The trial court applied a four-month rebuttable presumption under § 12-15-319(b) Ala.Code 1975 that abandonment continued through the filing of the petition.
On appeal, the Alabama Court of Civil Appeals initially dismissed for lack of jurisdiction; the Alabama Supreme Court reversed and remanded for consideration of remaining issues.
The court ultimately affirmed termination, holding that an unwed father who abandons a child may be deprived of other viable alternatives consistent with due process.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether clear and convincing evidence supports termination grounds.	Father argues insufficient evidence of abandonment or other grounds.	Mother argues the record shows abandonment, neglect, and lack of contact or support.	Yes; grounds supported; findings not legally erroneous.
Whether viable alternatives to termination were properly considered.	Father contends the court should have explored visitation or status quo options before terminating.	Mother/State contends no due-process requires alternatives where abandonment exists and where state should not compel continued parental relationship.	No; unwed father who abandons loses right to require exhausted alternatives; termination affirmed.

Ex parte Beasley, 564 So.2d 950 (Ala. 1990) (two-prong test for termination includes viable alternatives inquiry)
Ex parte Brooks, 513 So.2d 614 (Ala. 1987) (child support obligations and termination considerations in the best interests of the child)
Lehr v. Robertson, 463 U.S. 248 (U.S. 1983) (due-process protection for unwed fathers depends on demonstrated commitment to parenting)
Roe v. Conn, 417 F.Supp. 769 (M.D. Ala. 1976) (constitutional right to family integrity and limited state intervention)
J.B. v. Jefferson Cnty. Dep’t of Human Res., 869 So.2d 475 (Ala. Civ. App. 2003) (abandonment affects due-process rights to assert parental relationship)
Ex parte McInish, 47 So.3d 767 (Ala. 2008) (standard for review of factual findings under clear and convincing evidence)
Ex parte M.D.C., 39 So.3d 1117 (Ala. 2009) (termination does not terminate parental obligation to provide child support)
In re Stephenson, 513 So.2d 612 (Ala. 1987) (termination of parental rights considered in light of child’s best interests)