564 So. 2d 962 - Ex Parte Fowler’s Empirical Analysis

Citation profile

3 state decisions

Most-quoted passages

The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 3 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “"`The rule in Alabama is that, once a valid consent to adopt has been given and the child has been placed in the custody of the adoptive parents, consent can only be revoked for legal cause, such as where the consent was procured through fraud, undue influence, coercion, or other improper methods or where, under all the circumstances, the trial court finds it to be in the best interest of the child for it to be returned to the natural parents. Ex parte Nice, 429 So.2d 265 (Ala.1982), appeal after remand, Shuttleworth v. Catholic Family Services, 439 So.2d 1292 (Ala.Civ.App.1983); Williams v. Pope, 281 Ala. 416 , 203 So.2d 271 (1967), appeal after remand, 284 Ala. 456 , 225 So.2d 861 (1969) (citing In re Holman's Adoption, 80 Ariz. 201 , 295 P.2d 372 (1956); Lawshe [v. Seals], 443 So.2d 1249 [Ala. Civ.App.1983]; Wolf v. Smith, 435 So.2d 749 (Ala.Civ.App.1983); Hanlon v. Mooney, 407 So.2d 554 (Ala.Civ.App.), rev'd on other grounds, 407 So.2d 559 (Ala.1981); Davis v. Turner, 337 So.2d 355 (Ala.Civ.App. 1976); Graves v. Graves, 51 Ala.App. 601 , 288 So.2d 142 (Ala.Civ.App. 1973)).' "The wisdom behind that rule is self evident. If a natural parent has freely and knowingly given the requisite consent to the adoption of his or her child, and that consent has been acted upon by the adopting parents by their commencing adoption proceedings, and if the proposed adopting parents have relied on that consent by taking the child into their custody and care for a substantial period of time ”

   1 later decision quote this exact passage
   e.g. 864 So. 2d 333 - Klb v. Wmf