The Alabama Court of Civil Appeals has dismissed two appeals concerning the paternity and custody of a child born out of wedlock. The case involved T.L.L. (the father) and K.L.H. (the mother) and was decided on July 2, 2026. The court ruled that the juvenile court did not have the necessary jurisdiction to hear the case, which has implications for similar custody disputes in Alabama.
The case originated in the Mobile Juvenile Court, where both parents sought to resolve issues regarding the custody of their child, born in April 2020. The father filed a petition seeking custody, while the mother filed a counterclaim regarding paternity. However, the court found that the juvenile court lacked the authority to adjudicate custody disputes between parents, as outlined in Alabama law.
According to the Alabama Code, juvenile courts have limited jurisdiction and can only hear cases related to delinquency, dependency, or supervision of children. The court noted that the father did not allege that the child was dependent, which is necessary to invoke the juvenile court's jurisdiction. Instead, the father only sought custody, which is outside the scope of the juvenile court's authority.
The court explained, "A juvenile court shall exercise exclusive original jurisdiction of juvenile court proceedings in which a child is alleged to have committed a delinquent act, to be dependent, or to be in need of supervision." This means that custody disputes must be handled in circuit or district courts, not juvenile courts.
The appeals arose after the juvenile court mistakenly believed it had jurisdiction due to a standing order from the presiding judge of the Mobile Circuit Court. However, the Court of Civil Appeals determined that this standing order did not grant the juvenile court the authority to hear custody cases. The court stated, "We do not believe Rule 13(A) ... authorizes the standing order ... because it 'affects' the jurisdiction of the Mobile Juvenile Court in a manner that violates the constitutional limitation on the judicial rule-making power."
As a result, the court ruled that the juvenile court's judgment was void due to the lack of subject-matter jurisdiction. The court emphasized that a void judgment cannot support an appeal, leading to the dismissal of both appeals. The court instructed the juvenile court to vacate its earlier judgment.
This ruling has significant implications for custody disputes in Alabama. It clarifies that juvenile courts cannot hear custody cases unless they involve dependency issues. Parents involved in similar disputes will need to file their cases in the appropriate circuit or district courts to ensure that their cases are heard.
The dismissal of these appeals also reinforces the importance of understanding jurisdiction in family law cases. Parents seeking custody or paternity determinations must be aware of the specific legal frameworks that govern their cases to avoid jurisdictional pitfalls.
Looking ahead, it remains unclear whether either party will seek to appeal this dismissal or pursue their case in the appropriate court. There are no indications of related cases pending at this time.