Teen Parents Get Roughly Equal Parenting Time

Tennessee child custody case summary.

Tyler Cole Deaton v. Katlyn Nicole Williams

The child in this Madison County, Tennessee, case was born in 2016 to unwed parents who had just graduated from high school.  Following the birth, they moved into a “tiny” home in the backyard of the father’s parents.  The mother left with the child five months later.  A month later, the father filed a petition to establish paternity.  He initially sought equal parenting time, but later requested 285 days.  He argued that the mother’s lifestyle was unsuitable and that she did not provide attentive care.

A hearing was held before Judge Nathan B. Pride, who named the father the primary residential parent.  The mother received 80 days per year of co-parenting time.  However, that plan wasn’t to take effect until 2020.  In the meantime, the parties were to follow the prior order.  The mother then appealed to the Tennessee Court of Appeals.

The appeals court first noted that the relevant statute requires the parenting plan to be in the best interest of the child, and is governed by a number of statutory factors.   However, the statute does not require the court to specifically list all fifteen factors in its order.

The lower court had discussed many of the factors, but had also favored the father because of his shared gender.  Under Tennessee law, the gender of a party seeking custody is not a proper factor.

The appeals court also noted that the lower court seemed to have ignored at least two factors.  First of all, it ignored the fact that the mother had done most of the parenting responsibilities as primary caregiver.  It also failed to properly consider the importance of continuity.

For these reasons, the Court of Appeals reversed the lower court’s ruling.  Instead, it ordered that the mother should receive 183 days of co-parenting time and the father, 182.  It remanded the case for entry of such an order.  It also taxed the costs of the appeal upon the father.

No. W2018-00564-COA-R3-JV (Tenn. Ct. App. Feb. 21,  2020).

See original opinion for exact language.  Legal citations omitted.

To learn more, see Child Custody Laws in Tennessee.

See also Tennessee Parenting Plans and Child Support Worksheets: Building a Constructive Future for Your Family featuring examples of parenting plans and child support worksheets from real cases available on Amazon.com.