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M.C.G. v. Houston County Department of Human Resources, M.T., C.W.T., and C.T.

2026-08-28

Summary

Holding. The Court of Civil Appeals affirmed the juvenile court's judgments finding the children dependent and awarding legal custody to the paternal grandparents, holding that clear and convincing evidence supported the dependency finding based on the mother's limited financial circumstances at the time of the custody disposition in January 2026.

The mother appealed a juvenile court's determination that her children were dependent and awarded legal custody to their paternal grandparents. The dependency proceedings began in July 2024 after DHR alleged the mother had committed domestic violence and abuse while intoxicated. Although the mother completed all required services addressing those initial concerns, the juvenile court held a multi-day dispositional hearing culminating in January 2026 and found the children remained dependent. The mother argued the evidence did not support continued dependency because she had addressed the original issues that prompted DHR's intervention.

The appellate court applied the ore tenus standard of review, examining whether the evidence could have produced a firm conviction in the juvenile court that the children met the statutory definition of dependency. The court noted that a child's dependency status must be evaluated based on the parent's current circumstances at the time of custody disposition, not solely on the initial reasons for the dependency finding. The evidence showed the mother had been consistently unemployed throughout the proceedings, had minimal income from sporadic jobs and occasional odd work, and had not provided proof of stable employment despite testimony about a purported job offer. Additionally, the mother failed to maintain child support payments to the paternal grandparents. Although the mother acknowledged she maintained stable housing and was current on bills, and no witness testified the children lacked basic necessities, the court found the evidence of her limited financial means sufficiently supported a finding of dependency under the statute.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether evidence of a parent's limited financial means can support a finding of dependency
  • Whether a child's dependency must be evaluated at the time of custody disposition rather than at the initial adjudication
  • Whether the juvenile court properly applied the clear and convincing evidence standard
  • Whether a child can be found dependent on grounds different from those alleged in the initial petition

Procedural posture

The mother appealed from the juvenile court's January 2026 judgments finding her children dependent and awarding custody to the paternal grandparents following an adjudicatory hearing in November 2024 and a multi-day dispositional hearing held between August 2025 and January 2026.

Authorities cited

Opinion

majority opinion

Rel: August 28, 2026

Notice: This opinion is subject to formal revision before publication in the advance sheets of Southern Reporter. Readers are requested to notify the Reporter of Decisions, Alabama Appellate Courts, 300 Dexter Avenue, Montgomery, Alabama 36104-3741 ((334) 229-0650), of any typographical or other errors, in order that corrections may be made before the opinion is published in Southern Reporter.

ALABAMA COURT OF CIVIL APPEALS

SPECIAL TERM, 2026

CL-2026-0123 and CL-2026-0124

M.C.G.

v.

Houston County Department of Human Resources, M.T., C.W.T.,

and C.T.

Appeal from Houston Juvenile Court

(JU-24-446.01 and JU-24-447.01)

BOWDEN, Judge.

In July 2024, the Houston County Department of Human Resources

("DHR") filed dependency petitions in the Houston Juvenile Court ("the

juvenile court") seeking orders finding T.W.T. and N.S. ("the children")

CL-2026-0123 and CL-2026-0124

dependent. DHR's petitions alleged that the children's mother, M.C.G.

("the mother"), had committed acts of domestic violence and abuse while

intoxicated. The petitions resulted in a finding of dependency, and DHR

required the mother to complete services that were tailored to reducing

the risks posed by alcohol use and domestic violence, which she did. In

January 2026, the juvenile court entered judgments finding that the

children remained dependent and awarding legal custody of the children

to T.W.T.'s paternal grandparents M.T. and C.W.T. ("the paternal

grandparents"), i.e., the parents of C.T., T.W.T.'s father.1 The mother

appeals.

On appeal, the mother argues that the evidence did not support the

juvenile court's finding that the children were dependent because, she

says, she completed the services DHR required and the initial conditions

that precipitated DHR's intervention no longer exist. But a trial court can

find a child to be a dependent child for reasons other than the initial

reasons that caused the child to be found dependent. Here, the juvenile

court reasonably could have found that there was clear and convincing

1C.T. was adjudicated T.W.T.'s legal father during the proceedings

below.

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evidence demonstrating that the children remained dependent because

of the mother's limited financial means. Accordingly, we affirm the

judgments of the juvenile court.

Procedural History

DHR filed dependency petitions in July 2024. In November 2024,

the juvenile court held an adjudicatory hearing and entered orders ("the

dependency orders") that found the children to be dependent children.

The juvenile court then held a dispositional hearing over four days:

August 7, 2025, September 15, 2025, October 27, 2025, and January 12,

2026. On January 12, 2026, the juvenile court entered judgments ("the

dependency judgments") that found the children to be dependent and

transferred legal custody of the children to the paternal grandparents.

The dependency judgments did not contain specific findings of fact, but

the mother filed a postjudgment motion challenging the sufficiency of the

evidence to support the dependency judgments on January 20, 2026. The

mother's postjudgment motion was denied by operation of law on

February 3, 2026, and she timely filed notices of appeal on February 16,

2026.

Analysis

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The mother presents two arguments. Her first argument is that

DHR failed to present clear and convincing evidence demonstrating that

the children were dependent. Her second argument is that, because the

children are not dependent children, the juvenile court lacked

jurisdiction to transfer custody of the children to the paternal

grandparents. The mother's first argument is not persuasive, and we

pretermit discussion of the mother's second argument, which is

contingent on the success of her first argument.

I. Did DHR produce sufficient evidence to establish that the children

were dependent?

A. Standard of review

When a trial court presides over a bench trial, receives oral

testimony, and issues a judgment, we decide if the evidence was sufficient

to support that judgment using the ore tenus standard of review. W.S. v.

Houston Cnty. Dep't of Hum. Res., 426 So. 3d 838, 852 (Ala. Civ. App.

2025). In this case, the ore tenus standard of review requires us to

determine whether the juvenile court reasonably could have found that

there was clear and convincing evidence demonstrating that the children

were dependent. See § 12-15-311, Ala. Code 1975 (requiring finding of

dependency based on clear and convincing evidence); Ex parte Bodie, 377

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So. 3d 1051, 1056 (Ala. 2022)(describing the quantum of evidence that is

necessary for appellate affirmance of a judgment based on a factual

finding when the standard for a factual decision by the trial court was

clear and convincing evidence). Put simply, we must determine if the

evidence could have produced in the juvenile court " ' "a firm conviction

as to each element [of dependency] and a high probability of the

correctness of the conclusion." ' " Montgomery Cnty. Dep't of Hum. Res. v.

N.B., 196 So. 3d 1205, 1211 (Ala. Civ. App. 2015)(citations omitted).

"In passing on the question of the sufficiency of the evidence

as to a finding of dependency, this court does not reweigh the

evidence; instead, this court determines whether the juvenile

court, acting in its fact-finding role, reasonably could have

determined from its own weighing of the evidence that the

dependency of the child was proven by clear and convincing

evidence as that standard is defined above."

R.F.W. v. Cleburne Cnty. Dep't of Hum. Res., 70 So. 3d 1270, 1272 (Ala.

Civ. App. 2011). "We are not allowed to substitute our judgment for that

of the trial court, even when this court might have reached a different

result, unless the trial court's resolution of the facts is plainly and

palpably wrong." J.B. v. Cleburne Cnty. Dep't of Hum. Res., 992 So. 2d

34, 39 (Ala. Civ. App. 2008).

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Thus, when determining if the evidence was sufficient to support

the dependency judgments, we must examine the elements of dependency

and the evidence that DHR produced in support of those elements. We

must then determine if, based on that evidence, the juvenile court could

have had a "firm conviction" that DHR had established each element of

dependency and whether there is a "high probability" as to the

correctness of the juvenile court's conclusion that the children were

dependent, and we must do so without reweighing the evidence or

substituting our judgment for that of the juvenile court.

B. The elements of dependency

A child is dependent if he or she meets the statutory definition of a

dependent child, Ex parte L.E.O., 61 So. 3d 1042, 1046 (Ala. 2010), which

is set out in § 12-15-102, Ala. Code 1975. Under § 12-15-102, a dependent

child is a child who is in need of care and supervision, has been

adjudicated dependent, and who meets any of the circumstances

described in § 12-15-102(8)1. - (8)8. Sections 12-15-301(8)1. - 7. are

specific circumstances, and we have interpreted § 12-15-102(8).8. to mean

that a trial court can find a child dependent based on the "totality of the

circumstances." See Martin v. State ex rel. Dep't of Hum. Res., 502 So.

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2d 769, 771 (Ala. Civ. App. 1987)(interpreting former § 12-15-1(10)(m),

Ala. Code 1975, which contained substantially similar language as § 12-15-102(8)8., and stating that "this proposition gives the juvenile court the

authority to determine a child to be dependent under the totality of the

circumstances"). Thus, a child is dependent if (1) the child is in need of

care and supervision, (2) the child has been adjudicated dependent, and

(3) the child meets any of the specific circumstances set out in § 12-15-102(8)1. - .7. or the totality of the circumstances indicates that the child

is in need of the state's protection under § 12-15-102(8)8.

The juvenile court did not indicate in its dependency judgments

what circumstance or circumstances of dependency listed under § 12-15-102(8)1. – 8. apply. When a trial court does not make specific factual

findings in support of its dependency finding, as in this case, this court

must "presume that the juvenile court made those findings necessary to

support its judgment, provided that those findings are supported by the

evidence." J.C. v. Houston Cnty. Dep't of Hum. Res., 313 So. 3d 1137,

1139 (Ala. Civ. App. 2020) (citing K.C. v. Jefferson Cnty. Dep't of Hum.

Res., 54 So. 3d 407, 413 (Ala. Civ. App. 2010)). Thus, we presume that

the juvenile court made the factual findings necessary to find that the

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children are in need of care and supervision and that it found the

existence of one of the circumstances listed in §12-15-102(8)1. - 8.

DHR argues that the circumstances described in § 12-15-102(8)2.

and § 12-15-102(8)6. are relevant to these appeals. Those circumstances

describe a child "[w]ho is without a parent, legal guardian, or legal

custodian willing and able to provide for the care, support, or education

of the child," § 12-15-102(8)2., and a child "[w]hose parent, legal

guardian, legal custodian, or other custodian is unable or unwilling to

discharge his or her responsibilities to and for the child," § 12-15-102(8)6.

Relying on those provisions, we have held that "a parent's inability to

provide care for his or her child because of limited financial means can

serve as a basis for a finding of dependency." B.O. v. C.T., 416 So. 3d 1101,

1105 (Ala. Civ. App. 2024)(citing K.D.S. v. M.P., 392 So. 3d 760 (Ala. Civ.

App. 2023), citing in turn § 12-15-102(8)2. and § 12-15-102(8)6.).

The time at which a trial court finds a child dependent is also

relevant to appellate review of the sufficiency of the evidence to support

a dependency adjudication. Dependency proceedings occur in two stages:

an adjudicatory hearing, after which the trial court determines if the

child is dependent, and a dispositional hearing, after which the trial court

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determines what custody arrangement would serve the best interests of

the child. See § 12-15-310, Ala. Code 1975 ("Conduct of Adjudicatory

Hearings"); § 12-15-311 ("Dispositional Hearing"). The dispositional

hearing can occur immediately after the adjudicatory hearing or at a

later trial setting. Rule 25, Ala. R. Juv. P.; M.A. v. C.S., 382 So. 3d 1263,

1269 (Ala. Civ. App. 2023)("A juvenile court may either hold its

adjudicatory and dispositional hearings on the same date or it may hold

them on different dates.").

The evidence, however, must clearly and convincingly establish

that the child is dependent at the time of the disposition of custody.

A.N.F. v. D.F., [Ms. CL-2025-0736, May 1, 2026] ___ So. 3d ___ (Ala. Civ.

App. 2026); J.P. v. D.P., 260 So. 3d 862, 871 (Ala. Civ. App. 2018). Thus,

a trial court's initial finding of dependency, following an adjudicatory

hearing, is not necessarily dispositive as to the question of dependency at

the final disposition of the case. See M.D. v. S.C., 150 So. 3d 210, 213

(Ala. Civ. App. 2014)(holding that juvenile court's finding that child was

dependent at time of initiation of dependency proceedings was

insufficient to permit juvenile court to enter custody award or disposition

of child at time of dispositional hearing three years after proceedings

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were initiated). And we examine whether the evidence supports a finding

that a child is dependent at the time of the disposition of custody.

As a corollary to the requirement that a child be dependent at the

time of the trial court's custody disposition, a trial court must make its

determination that a child is a dependent child based on a parent's

"current circumstances," L.A.R. v. J.B.R., 401 So. 3d 1171, 1180 (Ala. Civ.

App. 2024). "There is no established formula for or time limitation on the

determination of what constitutes 'current circumstances' in the context

of a dependency action." Id.

With those principles in mind, we turn to the evidence before the

juvenile court.

C. The relevant evidence before the juvenile court

"The fundamental principle is that the decision of a court must be

based on evidence produced in open court lest the guaranty of due process

be infringed." Ex parte Berryhill, 410 So. 2d 416, 418 (Ala. 1982). The

juvenile court held an adjudicatory hearing in November 2024. Eleven

months later, the juvenile court held a dispositional hearing set over four

days: August 7, 2025, September 15, 2025, October 27, 2025, and January

12, 2026.

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CL-2026-0123 and CL-2026-0124

A court reporter's transcript of the November 2024 adjudicatory

hearing is not in the record. It does not appear, however, that the juvenile

court relied on evidence received at the November 2024 adjudicatory

hearing when entering its dependency judgments. The dependency

judgments do not reference evidence received or stipulations made at the

November 2024 hearing, and it is apparent that the juvenile court was

aware of its obligation to make a new dependency finding at the

conclusion of the dispositional hearing because the juvenile-court judge

stated, at the September 15, 2025, setting of the dispositional hearing,

that "[t]here must still be dependency, but it's disposition." Thus, transfer

of these appeals because of a lack of a transcript from the November 2024

adjudicatory hearing, is not necessary. Cf. S.J. v. K.J., 206 So. 3d 641,

644-45 (Ala. Civ. App. 2016)(transferring appeal because juvenile court's

judgment indicated that juvenile court had considered witness testimony

for which no transcript existed); C.J. v. Jefferson Cnty. Dep't of Hum.

Res., 76 So. 3d 268, 269 (Ala. Civ. App. 2011)(transferring appeal because

juvenile court relied on factual stipulations at hearing for which there

was no court reporter's transcript).

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The court reporter's transcripts from the dispositional hearing held

on August 7, 2025, September 15, 2025, October 27, 2025, and January

12, 2026, are in the record on appeal.2 The juvenile court did not take

judicial notice of any prior proceedings, cf. Ex parte State Dep't of Hum.

Res., 890 So. 2d 114, 118 (Ala. 2004) (listing evidence that can be

appropriately admitted by judicial notice at an adjudicatory hearing), but

it received two exhibits: an individualized-service plan dated June 27,

2025, and a "payment history," purporting to show support payments

that the mother had -- and had not -- made to the paternal grandparents.

1. Evidence received at the August 7, 2025, setting of the

dispositional hearing

2Those transcripts indicate that the juvenile court admitted

hearsay evidence over the mother's objection. The juvenile court

reasoned, correctly, that hearsay evidence is admissible at a dispositional

hearing. But a trial court cannot rely on hearsay evidence when making

a finding of dependency, and we have held that a trial court must make

a finding of dependency when it makes a custody disposition. The mother,

however, does not argue that the juvenile court improperly relied on

hearsay evidence when making its dependency finding at the time of the

custody disposition, nor did she assert a due-process argument below, see

Ala. R. Juv. P. 25A ("A dependency hearing shall be conducted consistent

with legal and due-process requirements …."), and we cannot preserve or

make those arguments for her.

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The mother testified about her employment history spanning the

period of July 2024 to August 7, 2025. She testified that she had been

employed as a service advisor at two car dealerships, had done

contracting work for Best Choice Roofing company, and had worked at

an Olive Garden restaurant. The mother testified that she receives

financial support from her family and that her grandmother has sent her

money to assist her in paying rent. She testified, however, that she is not

behind on her bills. She testified that she receives child-support

payments from the father of N.S. and that she forwards those payments

to the paternal grandparents.

With respect to her then-current employment status, the mother

testified that she was not employed on August 7, 2025. She testified that

she had an interview with Mercedes-Benz ("Mercedes") the next day.

2. Evidence received at the September 15, 2025, setting of

the dispositional hearing

The mother testified that she had worked for Mercedes for two

weeks but that her employment had been terminated. She testified that

her employment had been terminated because she had suffered a

bleeding disorder, despite having provided a doctor's excuse to Mercedes.

With respect to her employment status as of the September 15, 2025,

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setting of the dispositional hearing, the mother testified that she was

employed as an assistant general manager at a restaurant called "CB's."

She testified, however, that she had not yet started working but would

make $60,000 a year "plus bonuses."

The mother also provided testimony about her expenses. She

testified that her vehicle is paid off and that she has a monthly carinsurance premium of $90. She testified that her monthly phone bill is

$166 and that her electric bill usually runs between $200 and $250 per

month. She testified that she pays rent in the amount of $1,425 per

month and that she is required to pay rental insurance of $26 per month

and that her expenses average $300 a month for gasoline and $500 a

month for food. The mother testified that she would earn $4,800 per

month as assistant general manager at C.B.'s. She testified that that

income would meet the needs of her children. She testified that she had

a letter of employment from C.B.'s.

Lillian Nelson, the DHR caseworker assigned to the children's

cases, testified that her only concern regarding the mother's ability to

resume custody of the children was her financial stability.

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"[DHR's Counsel:] Do you have concerns at this time

related to whether it would be in the children's best interest

to be returned to [the mother]?

"[Nelson:] I am concerned about [the mother's] financial

stability.

"[DHR's Counsel:] Any other concerns?

"[Nelson:] No sir.

"[DHR's Counsel:] Do you perceive [the mother's]

situation to be stable?

"[Nelson:] No sir. "

Nelson testified that she knew where the mother worked, "but [the

mother] never gave [her] proof of employment."

3. Evidence received at the October 27, 2025, setting of the

dispositional hearing

The mother did not testify at the October 27, 2025, setting of the

dispositional hearing. Nelson testified that she had never seen a paystub

or letter of employment from the mother. According to Nelson, the longest

period of employment that the mother had reported to her was 90 days.

4. Evidence received at the January 12, 2026, setting of the

dispositional hearing

The mother testified that she had never started work at C.B.'s,

because, she testified, the schedule that she had been offered did not

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accommodate her duties as a mother. The mother testified that she was

not employed. She testified that she had "income, ways to make money."

She testified that she offered cleaning services for people who have homes

that have too many items. She testified that she has received around

$400 from that service. She testified that she still receives financial

support from family and that her family members has stepped in to assist

her.

The mother also testified about her support obligations. She

testified that she had received support from N.S.'s father every month,

that she had been ordered to forward that support to the paternal

grandparents, and that the last time she sent support to the paternal

grandparents was on July 11, 2025. The mother testified that she had

failed to send support since July 2025 because she had had the children

during her visitation periods and that she provides for them during that

time.

D. Whether the evidence supports a finding of dependency

If the evidence sufficiently establishes that a parent lacks a source

of income sufficient to provide for his or her expenses, this court will not

reverse a judgment finding that child dependent. A.T. v. A.G., 81 So. 3d

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385 (Ala. Civ. App. 2011); K.D.S. v. M.P., 392 So. 3d 760 (Ala. Civ. App.

2023). In A.T., the mother in that case, A.T., was not employed and

occasionally earned $250 per month in income as a babysitter or a

housecleaner. A.T. acknowledged that she relied on family members for

much of her support and to pay her court fines. She also testified that she

may have been eligible for Social Security disability benefits but that she

had not explored that option and, therefore, that possible source of

income was not yet available to her. The trial court found that A.T.'s

financial circumstances could improve but that, at that time, she was

unable to meet the children's needs. We affirmed the judgment finding

A.T.'s children dependent, reasoning, in part, that there was sufficient

evidence to support the trial court's finding that A.T. was unable to meet

the children's needs.

In K.D.S., the trial court received evidence regarding the income

and expenses of K.D.S., the mother in that case. K.D.S. received income

from her employment as a waitress, and her expenses included cost-ofliving expenses as well as court costs and support obligations. The

evidence demonstrated that K.D.S. was behind in making payments

toward court costs and child support. The trial court's judgment found

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the children dependent, and we affirmed that judgment. We reasoned

that "[t]he [trial] court could properly have drawn the inference from

[the] evidence that [K.D.S.'s] ability to earn income was insufficient to

cover all of her existing expenses, much less to cover those plus provide

support for teen and 'tween' children." K.D.S., 392 So. 3d at 764. We

stated:

"Although the mother's brief cites S.K. v. Madison County

Department of Human Resources, 990 So. 2d 887 (Ala. Civ.

App. 2008), which recites the proposition that poverty

' "should not be the criteria for taking away a wanted child

from the parents," ' 990 So. 2d at 903 (quoting In re Hickman,

489 So. 2d 601, 602-03 (Ala. Civ. App. 1986)), we would note

that both S.K. and Hickman involved appellate review of final

judgments terminating parental rights, whereas these

appeals involve determinations of dependency. To the extent

that the mother contends that the [trial] court could not

properly find the children dependent based solely upon her

inability to support them, this court held to the contrary in

A.T. v. A.G., 81 So. 3d 385 (Ala. Civ. App. 2011), affirming a

judgment determining that two children were dependent

because their mother was ' "unable to provide for the[ir] care,

support, and education at this time" '; this court noted that the

record in that case contained evidence indicating that the

mother had earned no more than $250 per month from odd

jobs and had relied on family members for her support and

paying court fees. See A.T., 81 So. 3d at 388, 389. The [trial]

court thus did not err in finding the children dependent."

K.D.S., 392 So. 3d at 764 (emphasis added).

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As in A.T. and K.D.S., the evidence in this case supports the

juvenile court's implicit determination that the children are dependent

based on the mother's limited financial circumstances. The mother was

consistently unemployed throughout the dependency proceedings. When

asked about her income at the most recent setting of the dispositional

hearing -- the setting in January 2026 -- the mother testified that she

was not employed but that she had other means to earn income. When

asked about those other means, the mother testified that she had earned

only $400 from cleaning houses. In contrast, the mother testified in detail

about her monthly expenses at the September 15, 2025, setting of the

dispositional hearing. She also acknowledged in January 2026 that she

was behind on her support payments to the paternal grandparents.

In light of the mother's testimony, and our holdings in A.T. and

K.D.S., we cannot say that the juvenile court could not have properly

concluded that, at the time of the January 2026 setting of the

dispositional hearing, the children were dependent "based solely on [the

mother's] inability to support them." K.D.S., 392 So. 3d at 764.

The mother argues, capably, that other evidence established that

that the children were not dependent due to her limited financial

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resources. The mother points out that the evidence was undisputed that

she had lived in the same three-bedroom rental home for over two years

and was current on all her bills. She points out that, if she were to again

receive custody of the children, she would retain the child-support

payments that she is currently required to forward to the paternal

grandparents. And she points out that not a single witness testified that

the children ever lacked food, shelter, clothing, or other basic necessities

while in the mother's care, even during the period when the mother had

unsupervised custody of the children four days per week. We also note

that Nelson testified that she had been in the mother's residence in June

2025 "to make sure that she had basic necessities for the boys," and

Nelson had agreed that the residence had appeared safe at that time.

The mother's argument, however, asks this court to reweigh the

evidence, which we cannot do. R.F.W., 70 So. 3d at 1272. Nor can we

substitute our judgment for the juvenile court's, even if we might have

reached a different result. J.B., 992 So. 2d at 40.

Lastly, we acknowledge the mother's well-reasoned argument that

the circumstances that led to the commencement of the dependency

proceedings could not have served as a basis for the juvenile court's

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subsequent dependency judgments. But, as the mother concedes in her

reply brief, a juvenile court can find a child dependent based upon

grounds not asserted in the initial dependency petition. M.M.S. v. D.W.,

735 So. 2d 1230, 1232 (Ala. Civ. App. 1999).

Conclusion

Sufficient evidence supported the juvenile court's finding that the

children are dependent because of the mother's limited financial

circumstances. Therefore, the judgments are affirmed.

CL-2026-0123 -- AFFIRMED.

CL-2026-0124 -- AFFIRMED.

Edwards, Hanson, and Fridy, JJ., concur.

Moore, P.J., concurs in the result, without opinion.

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