J.C. v. Cullman County Department of Human Resources (Appeal from Cullman Juvenile Court: JU-19-593.06)., CL-2024-0763

Cullman County DHR filed petitions to terminate the parental rights of J.C. (father) and S.C. (mother) regarding their two children due to ongoing substance abuse and child neglect concerns.
Evidence showed both parents repeatedly tested positive for methamphetamine and amphetamines and failed to engage consistently with DHR services, including drug screenings and communication.
The children were initially placed with their maternal grandmother but exhibited severe behavioral issues, including threats of self-harm and violence toward the grandmother, leading to multiple hospitalizations.
DHR ultimately placed the children in foster care after determining placement with the maternal grandmother was not successful or safe.
At trial, both parents denied serious drug problems despite evidence to the contrary and provided little cooperation with offered services; both tested positive for substances on the day of trial.
The juvenile court terminated the parental rights of both parents. Both appealed: the father alleging DHR did not make reasonable efforts to rehabilitate, and the mother arguing that placement with the maternal grandmother was a viable alternative.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether DHR made reasonable efforts to rehabilitate J.C.	DHR failed to use reasonable efforts	DHR provided services; J.C. failed to participate	Court found DHR's efforts reasonable; affirmed
Whether placement with maternal grandmother was a viable alternative	Placement with grandmother viable	Placement not viable due to children's behavior, grandmother withdrew petition	Court found placement not viable; affirmed

C.O. v. Jefferson Cnty. Dep't of Hum. Res., 206 So. 3d 621 (Ala. Civ. App. 2016) (sets clear and convincing evidence standard for termination of parental rights)
L.M. v. D.D.F., 840 So. 2d 171 (Ala. Civ. App. 2002) (reaffirms the high evidentiary burden for terminating parental rights)
Ex parte McInish, 47 So. 3d 767 (Ala. 2008) (addresses appellate review of factual findings under clear and convincing standard)
A.M.F. v. Tuscaloosa Cnty. Dep't of Hum. Res., 75 So. 3d 1206 (Ala. Civ. App. 2011) (parent must cooperate with DHR's reunification efforts)
M.A.J. v. S.F., 994 So. 2d 280 (Ala. Civ. App. 2008) (DHR's obligation is reasonable, not maximal, efforts)
Bowman v. State Dep't of Hum. Res., 534 So. 2d 304 (Ala. Civ. App. 1988) (DHR must prove no viable alternatives to termination)