In re Kylee T.

No. W2025-01055-COA-R3-PT · Court of Appeals of Tennessee · May 6, 2026 · No. W2025-01055-COA-R3-PT

Summary

The Tennessee Court of Appeals reviewed the termination of a mother's parental rights to her child. The court held that clear and convincing evidence supported abandonment by failure to financially support the child and that termination was in the child's best interest. The court affirmed the chancery court's judgment and remanded the case.

Holdings

  1. The trial court did not err in finding that Mother failed to substantiate her alleged payments for the child's cell phone and in crediting the testimony that the phone was broken and not used by the child.
  2. Clear and convincing evidence established statutory abandonment by failure to financially support the child during the four-month period immediately preceding the filing of the termination petition.
  3. Clear and convincing evidence established that termination of Mother's parental rights was in the child's best interest.
  4. The trial court's inclusion of one extra day in calculating the statutory four-month period was harmless error because it did not affect the analysis or outcome.

Questions Presented

  1. Whether the trial court erred in its factual findings concerning a cell phone allegedly provided by Mother to the child.
  2. Whether clear and convincing evidence established abandonment by failure to financially support the child during the four-month statutory period preceding the termination petition.
  3. Whether clear and convincing evidence established that termination of Mother's parental rights was in the child's best interest.

Disposition

affirmed

Cases Cited (22)

  • In re F.R.R., III, 193 S.W.3d 528, 530 (Tenn. 2006)(followed)
  • In re Carrington H., 483 S.W.3d 507, 522-24 (Tenn. 2016)(followed)
  • In re M.L.P., 281 S.W.3d 387, 393 (Tenn. 2009)(followed)
  • Jones v. Garrett, 92 S.W.3d 835, 838 (Tenn. Ct. App. 2002)(followed)
  • Keisling v. Keisling, 92 S.W.3d 374, 378 (Tenn. 2002)(followed)
  • In re Drinnon, 776 S.W.2d 96, 97 (Tenn. Ct. App. 1988)(followed)
  • Santosky v. Kramer, 455 U.S. 745, 754, 758-59, 769 (1982)(followed)
  • Lassiter v. Department of Social Services of Durham County, North Carolina, 452 U.S. 18, 27 (1981)(followed)
  • In re Bernard T., 319 S.W.3d 586, 596-97 (Tenn. 2010)(followed)
  • In re Audrey S., 182 S.W.3d 838, 861, 877-78 (Tenn. Ct. App. 2005)(followed)

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Cited In (0)

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