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Judge, Court of Appeals of Tennessee
IN RE JADEN H.
Court of Appeals of Tennessee · 2026-06-10
In this termination of parental rights action, maternal grandparents petitioned—with the biological mother’s consent—to terminate the father’s rights to his minor child, Jaden H., after gaining custody through juvenile court proceedings. The trial court found clear and convincing evidence supporting two statutory grounds: the father’s failure to manifest an ability and willingness to assume legal and physical custody or financial responsibility for the child, based on his lack of support despite claimed income, extensive criminal history involving drugs and reckless driving with the child present, and risk of substantial harm; and abandonment by willful failure to support during the relevant four-month period. It also determined by clear and convincing evidence that termination served the child’s best interest. On appeal, the Court of Appeals of Tennessee affirmed, holding that the trial court committed no reversible error in its findings or procedures.
family law
IN RE ALEXANDER B.
Court of Appeals of Tennessee · 2026-06-03
This case concerned a petition by Brittany A. and Ronald A. to terminate the parental rights of Aliyah H. (Mother) to her son Alexander B. (born 2020) on grounds including abandonment by failure to visit, persistence of conditions that led to the child's removal from her custody in 2022, and failure to manifest an ability and willingness to assume custody or responsibility. The trial court terminated Mother's rights after finding clear and convincing evidence of the first two grounds plus that termination served the child's best interest, but it rejected the third ground; it also rejected Mother's challenge to Ronald A's standing based on his criminal history and lack of legal relation to the child. On appeal, the Court of Appeals affirmed that Ronald A. had standing because he had maintained physical custody of the child for nearly a year under a prior court order. The court reversed the trial court's rejection of the third ground, holding that it too was established by clear and convincing evidence, and otherwise affirmed the termination and best-interest findings.
family law
IN RE MICHAEL S.
Court of Appeals of Tennessee · 2026-05-28
This case involved a petition by Jaime M. to terminate the parental rights of Brittany B. (Mother) to her young child, Michael S., on grounds including abandonment by failure to visit and failure to financially support the child, followed by a request to adopt the child. The trial court found clear and convincing evidence supporting both abandonment grounds and that termination was in the child's best interest, then granted the adoption by default after Mother did not appear. On appeal, the Court of Appeals affirmed the ground of abandonment by failure to support based on unrebutted evidence that Mother provided no financial support during the relevant three-month period before the amended petition. It reversed the failure-to-visit ground, however, because the evidence did not support that finding, and it vacated the best-interest conclusion for lack of sufficient statutory findings and analysis under Tennessee Code Annotated § 36-1-113(i), remanding the case for a proper best-interest review.
family law
MATTHEW HAWN v. SULLIVAN COUNTY BOARD OF EDUCATION
Court of Appeals of Tennessee · 2026-05-26
This partial concurrence and dissent addresses the appeal of a Sullivan County Chancery Court ruling in a case involving the dismissal of tenured teacher Matthew Hawn by the Sullivan County Board of Education under the Teacher Tenure Act. Judge Frierson concurs that Hawn did not engage in unprofessional conduct but agrees that the record established one act of insubordination, requiring modification of the trial court’s judgment to recognize this as a proven statutory ground for potential dismissal. He dissents from the majority’s holding that dismissal was excessive for an isolated incident, noting that the trial court had explicitly found no statutory violation and thus lacked authority to address the appropriateness of the penalty. Because the majority’s modification creates a statutory ground, Frierson would remand the case to the trial court for factual findings and legal conclusions on the proper level of discipline rather than deciding that issue on appeal.
labor & employment
JOHN WILLIAM OWENS ET.AL v. MEREDITH ELIZABETH OWENS
Court of Appeals of Tennessee · 2026-05-08
In this case, plaintiffs John William Owens and several members of the Hollis family sued Meredith Elizabeth Owens, alleging violations of federal and state wiretapping statutes based on her alleged use of a motion-activated recording device (described as a nanny cam) and spyware to capture private audio and video in their homes and vehicles, followed by disclosures of some recordings. After a two-day jury trial in which Owens and Owens testified, the jury found that Owens had not intentionally intercepted, used, or disclosed any communications in violation of the statutes; the trial court entered judgment for Owens and later denied the plaintiffs’ motion for judgment notwithstanding the verdict or a new trial. On appeal, the Tennessee Court of Appeals affirmed the judgment in full. The court reasoned that the jury’s verdict was supported by material evidence, that the trial court had correctly denied the plaintiffs’ summary-judgment and directed-verdict motions because genuine issues of fact existed regarding intent, and that the jury instructions were substantially accurate and not misleading.
criminal lawproceduretorts & liability
In Re Kylee T.
Court of Appeals of Tennessee · 2026-05-06
This case concerned a petition by the child's biological father and his wife to terminate the parental rights of the child's mother, Starquesha T., after the child had lived primarily with the petitioners since 2018. The Shelby County Chancery Court found that one statutory ground for termination was established by clear and convincing evidence and that termination served the child's best interest, based on factors including the mother's history of child abuse convictions, domestic violence, drug use, mental health issues, and repeated violations of court orders. The mother appealed, arguing errors in the best-interest analysis. The Tennessee Court of Appeals affirmed, holding that the trial court's findings on the statutory ground and best-interest factors were supported by clear and convincing evidence, with only one factor needing reweighing that did not alter the overall result. The court therefore upheld the termination of the mother's parental rights.
family law