In this Alabama case1, a juvenile court had terminated the parental rights of a mother. The mother filed a post-judgment motion, but it was denied. The mother then attempted to appeal the denial, sending her notice of appeal by fax to the clerk of the juvenile court. The mother was informed by telephone that her appeal would have to be mailed to the clerk, but she took no further action. The Alabama Court of Civil Appeals ruled that the mother had not filed a valid notice of appeal. Though she had sent the fax within the 14 days allowed for an appeal, court rules do not authorize a filing by fax. The court recognized that the mother was pro se (representing herself), but noted that the rules governing the operation of the Alabama courts are no different for pro se litigants than they are for persons represented by attorneys.
