Ala. Code § 26-10E-8: Consent to Adoption or Relinquishment for Adoption - by a Minor Parent.

(a) Prior to a minor parent’s giving express consent to an adoption or executing a relinquishment for adoption, a guardian ad litem shall be appointed to represent the interest of the minor parent whose consent is required. Any minor parent, 14 years of age or older, may nominate a guardian ad litem either prior to the birth of the adoptee or thereafter.

(b) A minor parent may give his or her implied consent to an adoption in the same manner as an adult parent under Section 26-10E-9. If a court finds by clear and convincing evidence that a minor parent has given implied consent to the adoption, the appointment of a guardian ad litem shall not be necessary. The implied consent of a minor parent may not be withdrawn.

(c) The express or implied consent of, or relinquishment by, a minor parent shall not be subject to revocation by reason of such minority.