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TENNESSEE: In re Angela E.
02.24.2010 | Termination of Parental Rights
The Supreme Court of Tennessee, at Jackson, in resolving a conflict within the Court of Appeal, reversed the judgment of the Court of Appeals which affirmed the trial court’s termination of appellant-father’s parental rights, holding that, even when a parent consents to the termination of his or her rights, the trial court’s written termination order must include written findings of fact and conclusions of law supported by clear and convincing evidence, the same as in a contested proceeding. The court found that the written findings and conclusions are required under Tenn. Code Ann § 36-1-113(c) and (k) and are also necessary in order to protect the parent’s due process rights.
Cite: No. W2008-00120-SC-R11-PT, 2010 Tenn. LEXIS 87 (Tenn. Feb. 16, 2010)
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