Ex Parte Cohen
In Ex Parte Cohen, 763 So. 2d 253, 256 (Ala. 1999), the applicable statute stated:
"Guidelines for child support are hereby established for use in any action to establish or modify child support, whether temporary or permanent."
Because the text referred to "any action," the Alabama court held that the provision encompassed all actions for child support, not merely actions concerning minor children. Id.