K.S. v. K.P. and C.P., [Ms. 2210156, May 13, 2022] __ So. 3d __ (Ala. Civ. App. 2022). The court (Edwards, J.; Thompson, P.J., and Moore, Hanson, and Fridy, JJ., concur) dismisses the mother’s appeal from the St. Clair Probate Court’s judgment of adoption. The court explains that “Alabama Code 1975, § 26-10A-17(a)(1), provides that notice of an adoption proceeding must be given to any person whose consent or relinquishment is required, ‘unless parental rights have been terminated pursuant to [Ala. Code 1975, §] 12-15-319.’ … Because her parental rights had been terminated, the mother had no cognizable claim to assert in the adoption proceeding, and, thus, had no basis to contest the adoption.” Ms. *4.
The court further holds that “[i]nsofar as the mother attempts to assert any potential rights of her family members to have been given notice of the adoption proceeding or to contest the adoption, we note that the mother cannot advance an argument on behalf of her relatives, assuming those relatives had any such rights. Ex parte Izundu, 568 So. 2d 771, 773 (Ala. 1990) (explaining that a person generally may not assert injuries to a third party).” Ms. *5.