To become an Alpha within the realm of Teen Wolf, a werewolf has to kill an Alpha in order to steal their position as pack leader and to obtain their strength. But in Season 3 of the series, Scott refuses to kill his enemies and becomes a "True Alpha."
Though rare, a True Alpha is born from a Beta who becomes a natural leader through the strength of character, virtue, and their "sheer force of will," Alan Deaton tells Scott in Season 3.
Derek becomes an Alpha at the end of Season 1 after killing his uncle, but his reign does not last long — he loses his status in Season 3 after giving up his spark to save his sister Cora Hale.
Eventually coming to terms with Scott being the leader of the pack, Derek becomes his Beta. But, at the end of Teen Wolf: The Movie, it seems Derek finally gains his Alpha status back.
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By sacrificing himself for the greater good, Derek certainly showed strength in his character and willpower, becoming a True Alpha.
You can now stream Teen Wolf: The Movie on Paramount+.