Ex parte W.L.K.

In this case, the probate court determined that W.L.K. (“the father”) had not impliedly consented to the adoption of M.M., his child. At that point, the probate court did not dismiss the action in accordance with Ala.Code 1975, § 26-10A-24(d)(3); instead, the probate court purported to transfer the proceeding to the juvenile court “in accordance with [Ala. Code 1975, § 26-10A-24(e) ].” . Section 26-10A-24(e) provides that, “[o]n motion of either party or of the court, a contested adoption hearing may be transferred to the court having jurisdiction over juvenile matters.” By its plain…