Summary
The Tennessee Court of Appeals held that a Tennessee juvenile court retained exclusive, continuing jurisdiction under the UCCJEA to modify a parenting plan involving a child residing in Arkansas. The court affirmed the denial of transfer to Arkansas and the refusal to set aside a default judgment entered as a sanction for failure to attend a deposition. It vacated the modified parenting plan because the trial court failed to conduct and explain the required best-interest analysis, and remanded for further proceedings.
Court
Court of Appeals of Tennessee
Jurisdiction
Tennessee Court of Appeals
Decision date
December 18, 2025
Docket number
M2024-00290-COA-R3-JV
Disposition
vacated
Questions Presented
- Whether the Tennessee juvenile court retained exclusive, continuing subject matter jurisdiction under the UCCJEA to modify the prior parenting plan after the child moved to Arkansas.
- Whether the juvenile court abused its discretion by refusing to decline jurisdiction and transfer the proceeding to Arkansas as an inconvenient forum.
- Whether the juvenile court abused its discretion by refusing to set aside the default judgment entered as a sanction for Mother's failure to appear at her deposition.
- Whether the juvenile court could modify the parenting plan without conducting an adequate statutory best-interest analysis after finding or implicitly finding a material change in circumstances.
Holdings
- The Tennessee juvenile court retained exclusive, continuing subject matter jurisdiction because the child and Father continued to have significant connections with Tennessee and substantial evidence concerning the custody issues remained available there.
- The juvenile court did not abuse its discretion by retaining jurisdiction in Tennessee rather than transferring the proceeding to Arkansas.
- The juvenile court did not abuse its discretion by refusing to set aside the default judgment entered as a sanction for Mother's failure to appear at her deposition.
- The juvenile court erred by adopting a modified parenting plan without adequately conducting and explaining the required best-interest analysis, even though the record supported an implicit finding of a material change in circumstances and even though the modification was entered by default.
Court Document
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