2016 ABA Blawg 100The American Bar Association has named this as one of the 100 best blogs for a legal audience for the second year in a row.

Seriously.

The ABA considers this little blog about Tennessee family law one of the best legal blogs.

In.

The.

World.

Click here to see the list — known as the “Blawg 100” — for yourself.

The Blawg 100 and some related articles appear in this month’s issue of the ABA Journal, which is the flagship magazine for the American Bar Association read by over 500,000 lawyers.

I want to thank all of you who read this blog, who share the posts with others through social media, who comment on the posts, and who recommend it to your friends and colleagues.

And I want to especially thank those of you who took the time to share your thoughts about this blog with the ABA.

Blawg 100 Herston

Being selected for the Blawg 100 is the biggest award a legal blogger can receive. I am honored by your support. Thank you, thank you, thank you!

celebrate-gif

Source: American Bar Association’s Blawg 100 (ABA Journal, December 1, 2016).

Information provided by K.O. Herston: Knoxville, Tennessee Divorce and Family-Law Attorney.

Posted by: koherston | December 2, 2016

Photo of the Week: Home on the Tennessee River

house on tennessee river

Information provided by K.O. Herston: Knoxville, Tennessee Divorce and Family-Law Attorney.

Facts: Mother and Father, the parents of two children, married and lived in Colorado for many years until moving to Tennessee. About six months after moving to Tennessee, Mother and Father separated. Over a year later, Mother filed for divorce.

moving-to-coloradoEach parent was designated the primary residential parent for one child, with the other parent receiving 85 days of parenting time per year.

In June 2015, Mother lost her job in Tennessee. Two months later, she notified Father of her intention to relocate to Colorado with the child for whom she was the primary residential parent. Mother stated she had been offered a job at a startup in Colorado. She also said the move would allow her to be close to her family.

Father filed a petition in opposition to Mother’s removal of the child.

The trial court found Mother did not have a reasonable purpose for her relocation, citing the “lack of experience” of her prospective employer in Colorado. The trial court also found the proposed relocation was not in the child’s best interest.

Father’s petition opposing Mother’s request to relocate with the child was granted.

Mother appealed.

On Appeal: The Court of Appeals reversed the trial court.

One of the most common postdivorce flashpoints occurs when the primary residential parent decides to move with his or her child or children to another city or state. One parent loses regular parenting time with the child as a result of the other parent’s move. The farther the move, the more intense the opposition because of the move’s effect on visitation and the ability of the other parent to foster and maintain an appropriate relationship with his or her child or children.

Under the parental relocation statute found at Tennessee Code Annotated § 36-6-108, the appropriate analysis depends upon the relative amount of time the parents spend with the child. In this case, Mother spends substantially more time with the child than does Father; therefore, the applicable statutory provision is Tennessee Code Annotated § 36-6-108(d)(1):

If the parents are not actually spending substantially equal intervals of time with the child and the parent spending the greater amount of time with the child proposes to relocate with the child, the other parent may, within thirty (30) days of receipt of the notice, file a petition in opposition to removal of the child. The other parent may not attempt to relocate with the child unless expressly authorized to do so by the court pursuant to a change of custody or primary custodial responsibility. The parent spending the greater amount of time with the child shall be permitted to relocate with the child unless the court finds:
(A) The relocation does not have a reasonable purpose;
(B) The relocation would pose a threat of specific and serious harm to the child that outweighs the threat of harm to the child of a change of custody; or
(C) The parent’s motive for relocating with the child is vindictive in that it is intended to defeat or deter visitation rights of the non-custodial parent or the parent spending less time with the child.

Thus, if the parents do not spend substantially equal intervals of time with the child, there is a legislatively-mandated presumption in favor of the relocating custodial parent. The burden is on the parent opposing the relocation to prove one of the three statutory grounds. If the opposing parent fails to do so, the court must allow the relocation.

Determinations of whether a proposed move has a reasonable purpose are fact-intensive and require a thorough examination of the unique circumstances of each case. Tennessee courts have consistently held that a salary increase and career advancement opportunities can be a factual predicate to constitute a reasonable purpose for relocation. They have also stated, however, that there must be more than a mere hope or belief of a better opportunity or a salary increase. Other pertinent economic factors include the relative significance of the salary increase, the cost of living in the proposed location compared to the present location, the firmness of the job offer, opportunity for career advancement, and economic betterment of the family unit.

After reviewing the record, the Court found Mother had a reasonable purpose for relocating:

In finding no reasonable purpose, the trial court focused almost exclusively upon Mother’s prospective employer, reasoning that the courts impose an implicit “requirement that there be some certainty with respect to the entity making the offer of employment.” The trial court found that [Mother’s prospective employer] had no experience in the particular type of business being developed . . . . While commending the objective of the company as “promising,” the trial court expressed concern that “there are as yet no results with which to gauge its prospects.” Similarly, although the salary projections for Mother of $60,000 to $150,000 (with bonuses) were “potentially lucrative; there was no certainty with respect to the ability of the entity to eventually make that payment.”

As stated above, Mother’s job prospects must be more than “a mere hope or belief.” They need not, however, be an absolute certainty. Contrary to the reasoning of the trial court, we find that Mother’s opportunity with [her prospective employer] was not speculative or uncertain enough to justify the trial court’s decision. [Mother’s prospective employer] had experience with startup companies and had already contributed substantial capital and raised additional capital for the venture at issue. Moreover, Mother had developed other job opportunities in Colorado. . . . There is no evidence to suggest Mother could not find other such opportunities in Colorado, if necessary.

*     *     *     *     *     *

In this case, Father did not produce any evidence of jobs available for Mother in the Chattanooga area. Father failed to prove that Mother’s proposed relocation to Colorado for job opportunities was not for a reasonable purpose. We conclude that the trial court erred in finding that Mother’s relocation was not for a reasonable purpose.

Thus, the trial court’s judgment was reversed and the case remanded for a new parenting schedule in light of Mother’s relocation.

Mouton v. Mouton (Tennessee Court of Appeals, Eastern Section, November 16, 2016).

Information provided by K.O. Herston: Knoxville, Tennessee Divorce and Family-Law Attorney.

Posted by: koherston | November 28, 2016

The Secret Superpower of a Shared-Custody Kid

This article by Rachelle Bergstein in The New York Times may be of interest.

The Secret Superpower of a Shared-Custody Kid

At 5:25 p.m., my mother pulled into our driveway. I saw my dad’s Cadillac waiting for us and glanced at Mom, whose broad smile instantly flattened. At 10 years old, I could already read her thoughts: Pickup time was 5:30, and she wasn’t willing to suffer accusations of tardiness, just because he was Mr. Punctuality.

Six-foot-five with jet-black hair, my father cut an intimidating figure, even if I knew that he liked nothing more than to turn his long arms and legs into props as he made up the words to songs and did goofy dances. Now, he was all business, and gestured at his watch angrily.

“I still have five minutes,” my mother said. She was generally vivacious, but when feeling threatened, she could transform herself into an ice queen.

“What’s the matter with you? Daylight saving time,” my father said. He’d been waiting an hour. She had made this mistake at least once before.

super kidThe color drained from my mother’s face as indignation gave way to embarrassment. Now, in the era of digital clocks that spring forward and fall back automatically, and cellphones that make it simple to communicate, it’s easy to forget that something as ordinary as daylight saving time could once have been so disruptive. But it was 1991, and ever since my parents got divorced, the day after we changed the clocks always felt slippery. My dad prided himself on his superior organizational skills while my mother lived in a house littered with scribbled notes-to-self to compensate for her bad memory.

That evening, I rushed out of one car and into the other. I didn’t need an overnight bag; my parents had done what they could to avoid a situation where I’d be packing and unpacking twice a week, and I had two rooms outfitted with essentials and beyond — two pairs of pink-framed glasses, two closets full of clothing, two favorite stuffed animals. Dad backed out of the driveway quickly, and said very little until we made it past the traffic light at the end of the block.

“Your mother,” he started, his lip twitching. I waited while he paused.

He opened his mouth to speak and then closed it again. Then, his jaw softened. “How long do you think she would have gone until she figured it out?”

I laughed, utterly relieved. “At least another day.”

I would learn, eventually, that all families have rules that – when violated – threaten to dismantle the whole arrangement. At the time, however, I thought I was the only kid in the world with two houses and a handwritten schedule in either kitchen; at the start of every month, my father listed the nights I would spend with him and then presented my mother with a copy. His diligence was a safeguard against situations just like this one, when he rang the doorbell to an empty house and then let the frustration and resentment wash over him.

My mom never made that mistake again. Daylight saving became another scribble on a Post-it note, another thing she was careful not to let her busy mind forget. And my dad let it go, for the most part – her blunder became a private joke for us, shorthand for the way such a smart, put-together woman could also be so ditzy.

My parents broke up when I was 5 years old, which means memories of life before shared custody are available to me, but limited. They set the terms of their divorce under the guidance of their lawyers, and I – as many young kids do — adapted and accepted the new parameters of my childhood.

But as I tipped into my teenage years, switching back and forth became more difficult. There were, of course, small aggravations, like when I accidentally left something I wanted at the other house. Yet that didn’t account for the new anxiety I felt at those twice-weekly hand-offs.

My two homes could not have been more different. By that time my parents had both happily remarried and they’d created new lives: my mom went back to school and our house was quiet, our conversations intellectual. My dad had two more little girls, and every time I stepped through the front door, it felt like I’d joined the circus. Mom stressed the importance of academic achievement; Dad pouted when, in our limited time together, I shut my door to do my homework. My mother thought manners were a sign of good breeding, and she frequently appended a “please” to the end of my requests. When I asked my father for “a glass of orange juice, please,” he ribbed me for behaving like a guest in my own kitchen.

My father’s car had become a portal between two parallel worlds. Somewhere along the way, every day had started feeling like the Sunday after daylight saving time. I straddled two time zones, both familiar, but conspicuous.

Now that I am an adult, with a husband and young son, I sometimes let myself feel sorry for the girl who frequently woke up in the morning not knowing where she was. And the Sunday morning after the clocks change still makes me uncomfortable.

But I know that not all children of divorce are lucky enough to have two parents who work so hard to stay connected. I’ve also come to appreciate the ways my childhood shaped me. Growing up across two households with two distinct sets of customs has made me observant and adaptive: I’m bilingual, in a sense.

That anxiety that plagued me as a teenager is gone, replaced with confidence in my fluency in both families. And like children who actually learn two languages from birth, that innate ability to switch back and forth serves me well, especially when I find myself in unfamiliar settings. It’s not just me: I often admire the way my husband, another shared-custody kid, moves so easily through new environments. He’s good at parties, but he’s also the kind of person who lands in a city for the first time and, within 24 hours, gets asked for directions.

The expected legacy of a joint custody childhood is a craving for stability, which my husband and I share. The unexpected one is real agility: a knack for adapting, switching gears, understanding the language of families, blending in.

We’ve learned that a family needs to be strong, yet flexible. Just as we can’t control the changing of the season or the clocks, we have to accommodate hiccups in the rhythms of our lives.

Source: The Secret Superpower of a Shared-Custody Kid (The New York Times, July 8, 2016).

Information provided by K.O. Herston: Knoxville, Tennessee Divorce and Family Law Attorney.

turkey half marathon

Information provided by K.O. Herston: Knoxville, Tennessee Divorce and Family-Law Attorney.

Posted by: koherston | November 23, 2016

Happy Thanksgiving!

K.O. Herston

Information provided by K.O. Herston: Knoxville, Tennessee Divorce and Family-Law Attorney.

Facts: Mother and Father are the unmarried parents of two children.

The parents eventually separated, and Father returned to his family home in Louisiana. An agreed order was entered naming Mother the primary residential parent. Father was granted visitation with the children for the entire month of June, one weekend per month, and alternating holidays.

For the next three years, the children moved back and forth between Mother’s home in Tennessee and the home of her father, i.e., the children’s maternal grandfather, in North Carolina. Father paid no support to Mother or Grandfather, although he did provide for the children’s needs when they were visiting with him.

At some point Grandfather began denying Father’s request for visitation.

Father filed a petition to change custody from Mother to Father.

Grandfather was allowed to intervene in the custody dispute because Grandfather alleged both parents failed to support and care for the children. Grandfather asked that custody be awarded to him.

The proof showed Father worked on an oil rig such that he worked for two weeks straight and then was off for two weeks. When he wasn’t working on the oil rig, Father lived with his grandmother.

The trial court awarded custody to Grandfather, finding that substantial harm to the children would result if custody were granted to Father. The trial court said that if the children moved to Louisiana with Father there would be “too many unknowns” because the court did not know who would care for the children or where they would go to school. The court also observed that a grant of custody to Father would basically be trading one grandparent for another considering his current work schedule and living situation.

Father appealed.

On Appeal: The Court of Appeals reversed the trial court.

In a contest between a parent and a nonparent, a parent cannot be deprived of the custody of the child unless there has been a finding of substantial harm to the child. Only then may a court engage in a general “best interest of the child” evaluation in making a determination of custody.

Tennessee courts have not undertaken to define the circumstances that pose a risk of substantial harm to a child. Such circumstances are not amenable to precise definition because of the variability of human conduct. However, the use of the modifier “substantial” indicates two things. First, it connotes a real hazard or danger that is not minor, trivial, or insignificant. Second, it indicates that the harm it must be more than a theoretical possibility. While the harm need not be inevitable, it must be sufficiently probable to prompt a reasonable person to believe that the harm will occur more likely than not.

The Court noted the trial court focused its analysis on Father’s past nonpayment of support and his employment schedule:

Father admitted that part of his reluctance to pay child support to Grandfather was because Grandfather thwarted his attempts to visit the Children and referred to Father as a “sperm donor.” During his testimony, Grandfather acknowledged that there had been times when Father had asked to see the Children but Grandfather refused his requests. Although Grandfather’s behavior does not justify Father’s non-payment of child support, it does negate Grandfather’s and Mother’s assertions that Father “abandoned” the Children or would fail to support the Children if they were in his custody. Father has demonstrated through the years that he is competent to provide for the Children while they are in his care. Father has also demonstrated a consistent desire to spend time with the Children when allowed to do so. Thus, Father’s past failure to pay child support, standing alone, is insufficient to establish substantial harm.

With regard to Father’s work schedule, the trial court stated that Father’s two-week-on, two-week-off schedule “essentially requires the Court to choose between the maternal grandfather and the paternal great-grandmother whom the Father has indicated would care for the children while he was working on the oil rig.” The court made this finding despite Father’s testimony that he was willing to seek full-time employment in Louisiana if the Children were placed in his care and despite the substantial support system that Father and the Children would enjoy due to the presence of the paternal grandmother and great-grandmother. Grandfather acknowledged that he related well to Father’s family and offered no concerns about their influence on the Children. Grandfather also admitted that the Children always enjoyed their co-parenting time with Father and his family. We therefore determine that a finding of substantial harm is not supported by clear and convincing evidence.

*     *     *     *     *     *

Based on the totality of the evidence, we determine that Mother and Grandfather did not clearly and convincingly establish that the Children would be exposed to a risk of substantial harm if they were placed in Father’s care. We conclude that the trial court erred by granting primary custody of the Children to Grandfather, who is a non-parent.

Thus, the award of custody to Grandfather was reversed and the case remanded to determine whether a material change in circumstance had occurred since the initial custody award to Mother and whether modifying the primary residential parent from Mother to Father is in the children’s best interest.

Vinson v. Ball (Tennessee Court of Appeals, Eastern Section, November 9, 2016).

Information provided by K.O. Herston: Knoxville, Tennessee Divorce and Family-Law Attorney.

Posted by: koherston | November 18, 2016

Photo of the Week: Goldfinch with Dandelion Florets

goldfinch dandelion

Information provided by K.O. Herston: Knoxville, Tennessee Divorce and Family-Law Attorney.

Posted by: koherston | November 17, 2016

Tennessee Family Law Update 2016: Johnson City

This morning we departed Knoxville before 6:00 a.m. en route to Johnson City and our final presentation of this year’s annual update seminar. We have a loyal following in the Tri-Cities, and it’s nice to see the same faces from year-to-year.

Here are some of the comments from today:

  • The gold standard of domestic relations seminars! —Bill Hampton, Esq.
  • A very effective presentation that helps me stay on top of the issues in family law. —Shelburne Ferguson Jr., Esq.
  • I always learn important information immediately applicable to my cases. This CLE helps keep me on top of my game and help my clients. —McKenna Cox., Esq.
  • All was superb. —Sarah Shults, Esq.
John teaching in Johnson City

John teaching in Johnson City

After enjoying lunch at Tupelo Honey, we made our way home to Knoxville, where life will now return to normal (or for what passes for normal in a family law practice).

home sweet home

Information provided by K.O. Herston: Knoxville, Tennessee Divorce and Family-Law Attorney.

Posted by: koherston | November 16, 2016

Tennessee Family Law Update 2016: Knoxville

After traveling to Memphis and Nashville, this morning we presented the seminar on our “home turf” in Knoxville.

Herston seminar

K.O. teaching in Knoxville

While the other cities are interesting in their own ways,  it’s always more fun to present this information to our colleagues with whom we handle our cases.

Some of today’s comments include:

  • This is always the most worthwhile CLE I attend each year. —Diane Messer, Esq.
  • Time flew by during the presentations. K.O. and John are well prepared. Excellent insights offered! —Heather Anderson, Esq.
  • Concise information and practical tips that will actually be useful. —Maria Danker, Esq.
  • Excellent as always! —Rebecca Bell Jenkins, Esq.
  • A great supplement to K.O.’s blog, which is a must read. —Jacqueline Kittrell, Esq.

Tomorrow morning we wrap things up in Johnson City. If you want to attend, it isn’t too late to sign up.

Tennessee family law update 2016

Information provided by K.O. Herston: Knoxville, Tennessee Divorce and Family-Law Attorney.

Posted by: koherston | November 15, 2016

Tennessee Family Law Update 2016: Nashville

This morning John and I returned to my hometown of Nashville to present this year’s annual update seminar.

Our hosts at the Nashville School of Law were gracious, as always. They provide an excellent venue for continuing legal education seminars.

nashville-school-of-law

Nashville School of Law

My mother lives in Nashville so she decided to “pop in” to today’s seminar. Even though I’m 44 years old, she had to stop by to see her “baby.”

Here are some of the comments from today:

  • Excellent update! Enjoyed the CLE. —Robert Curtis III, Esq.
  • Worth the drive from Chattanooga. —Leslie McWilliams, Esq.
  • Very thorough, helpful, and useful. —Byron Davis Jr., Esq.
  • Good pace of presentation. Well done! —Daryl South, Esq.

We’ll be in Knoxville tomorrow before finishing in Johnson City on Thursday. If you want to catch this year’s update, you can find the details here.

Information provided by K.O. Herston: Knoxville, Tennessee Divorce and Family-Law Attorney.

Posted by: koherston | November 14, 2016

Tennessee Family Law Update 2016: Memphis

We arrived in Memphis yesterday and promptly headed to Graceland. I had never been before. It’s hard to imagine having worldwide superstardom thrust upon you at such a young age. I have to give Elvis credit because I think he handled it better than most of us would have.

My wife and me outside Graceland

My wife and me outside Graceland

After stuffing ourselves at Central Ave. Barbeque, we watched the New England Patriots lose their rematch with Seattle.

We woke this morning and turned our attention to the reason for our trip to Memphis—our annual Update seminar.

It's showtime!

It’s showtime!

It was good to see some familiar faces (and some new ones) this morning. John’s son, Evan, stole the show with his cuteness.

Evan helping our wives run everything

Evan helping our wives run everything

After the loooong drive to Nashville this afternoon, we arrived just in time for rush-hour traffic! We eventually made it safely and are gearing up to do it all again tomorrow at the Nashville School of Law.

If you want to see us in Nashville, Knoxville, or Johnson City, click here for details.

Information provided by K.O. Herston: Knoxville, Tennessee Divorce and Family-Law Attorney.

Posted by: koherston | November 11, 2016

We’re On the Road Again!

At long last, our seminar tour has finally arrived. We’re packing up, hitting the road, and looking forward to seeing our friends in Memphis and Nashville before we return to East Tennessee with stops in Knoxville and Johnson City.

If you haven’t signed up, it’s not too late (although it’s pretty darn close).

Click here for details!

Information provided by K.O. Herston: Knoxville, Tennessee Divorce and Family-Law Attorney.

Posted by: koherston | November 11, 2016

Photo of the Week: Snow Days

snow day

Information provided by K.O. Herston: Knoxville, Tennessee Divorce and Family-Law Attorney.

Facts: Mother and Father, who were never married, entered an agreed parenting plan establishing a long-distance parenting schedule because of Mother’s relocation with the children to Ohio (and later Nevada). The agreed parenting plan designated Mother as the primary residential parent.

tennessee divorceVery shortly thereafter, Father petitioned to change custody on the grounds that the agreed parenting plan had been procured by fraud. Specifically, Father claimed Mother represented in their negotiations that she was working as an “independent contractor.” Father belatedly learned that Mother actually was working as a licensed prostitute in Nevada at the Moonlight Bunny Ranch.

At the hearing, the proof showed the children were not exposed to Mother’s occupation. Furthermore, by the time of trial, Mother was out of the prostitution business and employed as a social worker in Nevada after having received her master’s degree in social work and her provisional license from the state of Nevada for social work.

The trial court found there was a material change in circumstances for the children because of Mother’s deceit and Mother’s occupation as a prostitute. The trial court further found it was in the children’s best interest that custody be awarded to Father. Notably, the trial court did not conduct a statutory best interest analysis of any sort.

Mother appealed. The Court of Appeals remanded the case to the trial court to conduct the statutory best interest analysis. I covered that appeal here.

On remand, neither party chose to present new evidence. The trial court conducted the required best interest analysis and, again, ruled to change custody from Mother to Father.

For the second time, Mother appealed.

On Appeal: The Court of Appeals reversed the trial court (again).

The Court reversed the trial court’s finding that Mother’s temporary employment as a licensed prostitute constituted a material change of circumstances warranting modification of the parenting plan:

To qualify as “material,” the change in circumstances must be one that affects the child’s well-being in a meaningful way. There is no evidence in this record showing that Mother’s occupation as a licensed prostitute in Nevada has affected the children. . . . Because Father failed to establish the children were affected, we must hold that the evidence preponderates against the finding that Father established that Mother’s work as a licensed prostitute met the legal standard for a material change in circumstances.

The Court did find, however, that Mother’s hostility to Father and Stepmother constitute a material change of circumstances. With that threshold finding, the Court proceeded to consider the children’s best interest.

In child custody cases, the needs of the children are paramount; the desires of the parents are secondary. Questions related to custody and visitation should be directed toward promoting the child’s best interest placing him or her in an environment that will best serve his or her physical and emotional needs. To make this determination, Tennessee courts must consider the statutory factors found in Tennessee Code Annotated § 36-6-106(a).

Determining a child’s best interest is a fact-sensitive inquiry that does not call for rote examination of each of the relevant factors in any determination of whether the sum of the factors tips in favor of or against the parent. The relevancy and weight to be given each factor depends on the unique facts of each case.

The Court complained that much of the trial court’s best interest analysis relied on its finding that Mother’s work in prostitution was ongoing, which the Court found to be entirely speculative and contradicted by the evidence:

There is significant and substantial evidence supporting the conclusion that Mother is no longer working as a prostitute. The court admitted into evidence earnings statements from Mother’s current employment at the social worker, as well as copies of her provisional Nevada social workers license, and related diplomas and academic awards. As previously noted, there was no testimony at trial indicating that she was currently working as a prostitute.

After examining the evidence in detail, the Court found the trial court abused its discretion:

It is clear that both parents at times have acted in a manner that failed to put the children’s interest first. However, we find the trial court relied heavily on a finding that Mother’s work in prostitution was ongoing to reach its conclusion that it is in the children’s best interest to designate Father as the primary residential parent. We find the evidence does not support this conclusion. The trial court also failed to take into account Father’s a significant child support and medical arrearages of $10,027. We also find it significant that Father admitted to using illegal drugs in the family home when the children were present. For all of these reasons, we hold that the evidence preponderates against the trial court’s finding that the best interest of the children mandates that Father be the children’s primary residential parent. For reasons stated above, the trial court abused its discretion in designating Father as the primary residential parent.

Thus, the trial court’s judgment was reversed. Mother was restored to being the children’s primary residential parent. The Court of Appeals even ordered Father to deliver the children to Mother in Nevada “no later than 20 days following the entry of this order.”

K.O.’s Comment: (1) Because of the tremendous deference given to a trial court’s findings and discretionary decisions, it is rare for the Court of Appeals to find that the trial court abused its discretion. This case is among the few that show it can happen.

(2) When I covered the first appeal, I chastised the Court for including information that could identify the parties. This time around, the Court changed course, explaining:

In order to preserve the anonymity of the minor children and related individuals in this case, involving, as it does, sensitive matters, we have abbreviated their names.

C.W.H. v. L.A.S. (Tennessee Court of Appeals, Eastern Section, October 31, 2016).

Information provided by K.O. Herston: Knoxville, Tennessee Divorce and Family-Law Attorney.

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