State ex rel. Moody v. Roker (Tennessee 2021)

No. W2019-01464-COA-R3-JV (Tenn. App. 2021)
March 2021

A ruling in a final order must be supported by findings of fact and conclusions of law. The mother, a Georgia resident, used the child support program to establish paternity and support pursuant to the Uniform Interstate Family Support Act. The father was incarcerated in Tennessee. The father filed numerous pretrial motions. Significant to this appeal, he filed a motion to participate in the hearing and for transportation. The trial court held a hearing, which was attended by the child support attorney. The final order adjudicating the father’s paternity and set support. The father appealed. The appellate court vacated the order and remanded for a new trial. The father raised several issues, including the court’s jurisdiction over him. The appellate court reversed due to the fact the trial court didn’t rule on the father’s pretrial motions prior to the hearing, including his motion to participate. That meant he wasn’t able to attend the hearing and present evidence and he had no explanation for this determination. The final order didn’t contain required findings and wasn’t based on properly admitted evidence.