N.B. v. J.C.R., 204 So. 3d 887

Putative father (J.C.R.) filed a juvenile-court petition alleging the child was dependent and seeking custody and pendente lite relief; a separate paternity action was filed in district court.
Juvenile court appointed GAL, denied pendente lite custody, granted limited visitation, and scheduled a trial; mother (N.B.) appeared, sought continuances, and was represented.
Mother later moved to dismiss, arguing the petition alleged only a parental custody dispute (not dependency) and that service on the child (age 12+) was defective under Rule 13(A)(1), Ala. R. Juv. P.
Juvenile court reviewed the pleadings and concluded the petition alleged only a custody dispute, not dependency, and transferred the case to the Shelby Circuit Court under § 12-11-11.
Mother moved to set aside the transfer and then sought a writ of mandamus from the appellate court to vacate the transfer, arguing juvenile court lacked authority to transfer (should have dismissed), confidentiality was violated, and personal jurisdiction/service issues existed.
Appellate court denied mandamus, holding the juvenile court could transfer under § 12-11-11 as interpreted in Ex parte E.S.; confidentiality concerns and service arguments did not justify disturbing the transfer.

Issue	Plaintiff's Argument (Mother)	Defendant's Argument (Putative Father / Juvenile Court)	Held
Whether juvenile court may transfer a petition it finds not to allege dependency to circuit court	Juvenile court must dismiss for lack of subject-matter jurisdiction; it cannot transfer to another court	§ 12-11-11 authorizes transfer to the proper court in the same county when case belongs elsewhere	Transfer was permitted under § 12-11-11 as interpreted by Ex parte E.S.; mandamus denied
Whether transfer violated juvenile-file confidentiality protections	Transfer improperly exposes juvenile legal files; confidentiality statute forbids disclosure	Confidentiality statute still applies after transfer; sealing procedures exist in circuit court	Transfer does not warrant vacatur; confidentiality protections can be preserved via circuit-court procedures
Whether juvenile court had personal jurisdiction over mother/child due to defective service	Service on the child (12+) under Rule 13(A)(1) and on mother was defective; no personal jurisdiction	Mother voluntarily appeared, litigated, and waived any service/jurisdiction objections	Service objection was waived by mother’s appearances and filings; issue is moot regarding child because court deemed matter non‑dependency

Ex parte E.S., 205 So.3d 1245 (Ala. 2015) (interpreting § 12‑11‑11 to require transfer of cases filed in the wrong local court rather than outright dismissal)
Ex parte MedPartners, Inc., 820 So.2d 815 (Ala. 2001) (mandamus is appropriate to challenge improper transfer orders)
J.A. v. C.M., 93 So.3d 953 (Ala. Civ. App. 2012) (juvenile court must dismiss dependency petition if child is not dependent; court lacks authority to adjudicate custody absent other jurisdictional basis)
Ex parte M.M.T., 148 So.3d 728 (Ala. Civ. App. 2014) (juvenile court lacked subject‑matter jurisdiction over a pure custody dispute)
Ex parte Blankenship, 893 So.2d 303 (Ala. 2004) (actions other than dismissal taken by a court lacking jurisdiction are void)