W.S. II v. Houston County Department of Human Resources (Appeal from Houston Juvenile Court: JU-21-344.02)., CL-2023-0794

The Houston Juvenile Court terminated the parental rights of W.S. II (father) and E.A. (mother) over their child, E.H.S., following a dependent child action brought by the Houston County Department of Human Resources (DHR).
Both parents challenged the court's subject-matter jurisdiction under the Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA), arguing Alabama did not qualify as the "home state."
The child was born in Alabama after the mother, a Florida resident, crossed state lines intending to avoid Florida authorities; both the mother and child tested positive for methamphetamine at birth.
DHR initiated dependency proceedings shortly after birth, and the child was placed with Alabama foster parents; the mother was incarcerated in Florida, and the father was absent and had unmet legal paternity for over a year.
The trial court initially exercised emergency jurisdiction, which was questioned on appeal; the case was remanded for further jurisdictional findings, then affirmed on return from remand after reviewing supplemental evidence.
The mother also argued that the court failed to consider less drastic alternatives to termination, including placement with the father or paternal relatives, which the court rejected.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Alabama juvenile court had jurisdiction under UCCJEA	Alabama lacked home-state/significant-connection	Alabama obtained jurisdiction as no	Alabama had jurisdiction under §30-3B-201(a)(4) as no other
	jurisdiction; Florida should have had jurisdiction	other state qualified under UCCJEA	state qualified under UCCJEA; emergency jurisdiction proper
			and ripened into exclusive jurisdiction.
Whether the parents were provided viable alternatives to termination	Less drastic alternatives existed—placement with	No suitable relatives or viable	No viable alternatives existed: father unfit and relatives
	father or paternal relatives	alternatives existed, child bonded	untimely or ineligible; child best interests served by
		to foster parents	adoption by foster family.
Whether grounds existed to terminate parental rights under law	Did not directly contest on appeal	Statutory grounds met—history of	Clear and convincing evidence supported termination:
		drug use, prior terminations	substance abuse, prior rights terminations, unfitness shown.
Whether temporary emergency jurisdiction can become permanent	Asserted it cannot ripen without explicit order	Argued it ripened via dependency	Court held temporary emergency jurisdiction did not
	language	judgment and prolonged custody	ripen into permanent unless expressly stated, but Alabama had
			jurisdiction under UCCJEA alternative basis anyway.

H.T. v. Cleburne Cnty. Dep't of Hum. Res., 163 So. 3d 1054 (Ala. Civ. App. 2014) (hospital stay at birth insufficient for home state jurisdiction under UCCJEA)
Kennedy v. Boles Invs., Inc., 53 So. 3d 60 (Ala. 2010) (ore tenus standard of review for trial court factual findings)
Allstate Ins. Co. v. Skelton, 675 So. 2d 377 (Ala. 1996) (presumption of correctness for ore tenus trial court findings)
P.S. v. Jefferson Cnty. Dep't of Hum. Res., 143 So. 3d 792 (Ala. Civ. App. 2013) (clear and convincing evidence necessary for termination of parental rights)
Ex parte T.V., 971 So. 2d 1 (Ala. 2007) (two-prong test for termination of parental rights: grounds and alternatives)