Facts: Father was verbally and (in one incident) physically abusive to his children. The trial court modified the parenting plan to suspend all of Father’s visitation and set forth no means by which visitation could be restored. Father appealed, arguing the trial court’s decision effectively terminated his parental rights.

The Court of Appeals agreed with Father and sent the case back to the trial court “to establish a suitable schedule of supervised visitation.” This result is consistent with other cases holding that a court should establish the least restrictive visitation schedule that will allow the maintenance of a parent-child relationship. The Court of Appeals also reminded Mother of her obligation to encourage the children to have “a close and continuing parent-child relationship” with Father (for more on that issue, see my earlier post).

Smith v. Dorsett (Tenn. Ct. App., Feb. 4, 2010).