In re Harper A.

No. E2025-00869-COA-R3-PT · Court of Appeals of Tennessee · January 13, 2026 · No. E2025-00869-COA-R3-PT

Summary

The Tennessee Court of Appeals reviews an order terminating a mother's parental rights to two children. The court affirms three statutory grounds for termination and vacates the finding concerning failure to manifest an ability and willingness to assume custody or financial responsibility because the trial court's findings were insufficient. It also vacates the best-interests determination and remands for additional findings of fact and conclusions of law.

Holdings

  1. The trial court's order on this ground contained only conclusions of law and lacked the necessary findings of fact required by Tennessee Code Annotated section 36-1-113(k).
  2. The ground of persistent conditions was proven by clear and convincing evidence.
  3. The grounds of substantial noncompliance with the permanency plan and abandonment by failure to provide a suitable home were proven by clear and convincing evidence.
  4. The trial court's order on best interests contained insufficient findings of fact and conclusions of law as required by Tennessee Code Annotated section 36-1-113(k).

Questions Presented

  1. Whether the trial court erred when it determined that termination of Mother's parental rights was in the best interests of the children.

Disposition

affirmed_in_part_vacated_in_part_and_remanded

Cases Cited (30)

  • In re Carrington H., 483 S.W.3d 507 (Tenn. 2016)(followed)
  • In re Neveah M., 614 S.W.3d 659 (Tenn. 2020)(followed)
  • In re Kaliyah S., 455 S.W.3d 533 (Tenn. 2015)(followed)
  • In re Bernard T., 319 S.W.3d 586 (Tenn. 2010)(followed)
  • In re Markus E., 671 S.W.3d 437 (Tenn. 2023)(followed)
  • In re Valentine, 79 S.W.3d 539 (Tenn. 2002)(followed)
  • In re Audrey S., 182 S.W.3d 838 (Tenn. Ct. App. 2005)(followed)
  • In re N.B., 285 S.W.3d 435 (Tenn. Ct. App. 2008)(followed)
  • In re Trenton B., No. M2022-00422-COA-R3-PT, 2023 WL 569385 (Tenn. Ct. App. Jan. 27, 2023)(followed)
  • In re Zaylee W., No. M2019-00342-COA-R3-PT, 2020 WL 1808614 (Tenn. Ct. App. Apr. 9, 2020)(followed)

Showing top 10 of 30.

Cited In (0)

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