S.C. v. Cullman County Department of Human Resources (Appeal from Cullman Juvenile Court: JU-19-594.06)., CL-2024-0780

Cullman Juvenile Court terminated the parental rights of J.C. (father) and S.C. (mother) to their two children after proceedings initiated by the Cullman County Department of Human Resources (DHR).
DHR filed petitions in May 2024, citing unaddressed parental drug use, inadequate living conditions, and neglect.
Evidence included repeated positive drug tests (methamphetamine, amphetamines, marijuana), poor home conditions, lack of cooperation from parents, and children's behavioral deterioration in the grandparents’ care.
DHR provided the parents with substance-abuse assessments, psychological evaluations, parenting classes, and attempted ongoing communication, but the parents only sporadically complied and remained uncooperative.
The maternal grandmother initially assumed care under a safety plan, but could not manage the children due to their increasingly dangerous behaviors, leading to hospitalization and withdrawal of her custody request.
Parents appealed, arguing DHR’s efforts at reunification were insufficient (father) and that placement with the maternal grandmother was a viable alternative (mother).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether DHR made reasonable efforts to rehabilitate father	DHR failed to provide services	Reasonable efforts made but father uncooperative	Affirmed: Services were reasonable
Whether viable alternatives to termination existed	Custody with grandmother viable	Placement failed, grandmother no longer willing	Affirmed: No viable alternative existed

M.W. v. Marshall Cnty. Dep't of Hum. Res., 399 So. 3d 287 (Ala. Civ. App. 2024) (discussing appellate standard for clear and convincing evidence in termination cases)
Montgomery Cnty. Dep't of Hum. Res. v. A.S.N., 206 So. 3d 661 (Ala. Civ. App. 2016) (explaining reasonable efforts requirement for DHR)
A.M.F. v. Tuscaloosa Cnty. Dep't of Hum. Res., 75 So. 3d 1206 (Ala. Civ. App. 2011) (parent must make themselves available for reunification efforts)
G.P. v. Dale Cnty. Dep't of Hum. Res., So. 3d (Ala. Civ. App. 2024) (DHR must prove lack of viable alternative by clear and convincing evidence)