Facts: Unmarried parents appeared in juvenile court to establish a parenting schedule and child support. After a trial, the magistrate ordered a parenting plan designating Mother as the primary residential parent and establishing Father’s parenting schedule. The magistrate did not rule on child support.

Father filed a request for rehearing before the juvenile court judge per TCA § 37-1-107.

The juvenile court judge affirmed the magistrate’s findings in a one-sentence order.

Father appealed.

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

First, Tennessee’s appellate courts must consider their subject-matter jurisdiction, whether or not it is presented for review. Because the juvenile court did not adjudicate the child support issue, the Court of Appeals lacked subject-matter jurisdiction. Without a ruling on child support, there was no final, appealable judgment to which appellate jurisdiction could attach.

Second, TCA § 37-1-107(d)(1) was changed in 2023 to reduce the juvenile court judge’s responsibilities upon rehearing. The amended statute states that, within 10 days after entry of the magistrate’s order, a party may ask for a review of the record by the juvenile court judge. The request must include specific findings to which the party objects, the grounds for the objection, and the party’s proposed findings and conclusions.

This case presents an issue of first impression, namely, what duty is imposed by subsections (D) and (E), which state:

(D)  The juvenile court judge shall afford the magistrate’s findings, conclusions, and recommendations a presumption of correctness. The judge shall modify the magistrate’s findings only when, after review, the judge makes a written finding that an abuse of discretion exists in any or all of the magistrate’s findings, conclusions, or recommendations.

(E)  The judge shall issue written findings, conclusions, or recommendations or may schedule the matter for a new hearing of any issues the judge deems necessary, with notice to all parties.

The Court was critical of the juvenile court judge’s failure to make the necessary findings:

Turning to the language of the statute, each of these subsections provides that the juvenile court judge “shall” make certain findings, conclusions, or recommendations. Subsection (D)’s “written finding” provision is only applicable when the judge finds an abuse of discretion in the magistrate’s ruling. Subsection (E), however, states that the juvenile court judge “shall” make “written findings, conclusions, or recommendations” without specifying that those findings or conclusions are required only when the magistrate’s ruling is reversed. It therefore appears that subsection (D) applies irrespective of whether the magistrate’s ruling is affirmed, reversed, or modified.

Moreover, Tennessee courts have repeatedly held that similar language in rules and statutes that a trial court “shall” make findings and conclusions or state legal grounds imposes a mandatory duty on ruling courts to do so.

When courts have such a mandatory obligation, simply stating the trial court’s decision, without more, does not fulfill that duty. Instead, the trial court’s ruling must explain how the court reached its decision. Thus, while the 2023 amendment to section 37-1-107(d) significantly reduced the juvenile judge’s responsibilities upon rehearing, it did not eliminate the duty to independently review the magistrate’s ruling and make appropriate findings of fact, conclusions of law, or recommendations following that review. Indeed, in many ways, the duty imposed on the juvenile court judge is similar to the duty of this Court in adjudicating this appeal.

Respectfully, the [juvenile] court in this case did not fulfill this duty, as it did nothing more than simply state its decision without explanation. Indeed, although Father filed a lengthy objection to the magistrate’s ruling alleging a host of errors, the trial court’s decision comprises only one sentence: “The Court has reviewed the magistrate’s order, the pleadings, and the entire file, and finds no abuse of discretion exists in any or all of the magistrate’s findings, conclusions, or recommendations.” Thus, the trial court’s ruling contains a single unsupported conclusion and no factual findings of any kind. Moreover, the trial court’s ultimate conclusion is not explained in any way. As a result, the trial court’s decision does not comply with the mandatory language of § 37-1-107(d)(1)(E). Under the circumstances, we have held that it is appropriate to vacate the judgment and remand it to the trial court for the entry of a more detailed order.

The Court remanded the case to the juvenile court to adjudicate child support and for the entry of an order that complies with section (E) of the juvenile judge rehearing statute.

K.O.’s Comment: I believe the single-sentence-affirmation practice of the juvenile court judge is widespread throughout Tennessee. I’ve seen it myself. This is not an isolated incident or a one-off. So, this is an opinion that all Tennessee family-law attorneys need to be aware of.

Source: Barton v. Keller (Tennessee Court of Appeals, Western Section, April 8, 2025).

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