Snipes v. State Department of Human Resources
542 So. 2d 282 (Ala. Civ. App. 1989)

The court approves termination of the mother's parental rights. The child had been diagnosed with FAS and a number of other problems. The mother's inability to care for the special needs of the child was a major factor in the determination to terminate her parental rights. 542 So. 2d at 284.