State of Tennessee Ex Rel. Barbara E. Catalano v. William R. Woodcock

In this post-divorce child support case, we granted interlocutory appeal to determine whether the Knox County Fourth Circuit Court (“trial court”) erred by finding that the mother was entitled to ongoing and/or retroactive child support from the father for the parties’ adult disabled child. In October 2001, the mother had been granted a default divorce judgment by the Rutherford County Circuit Court (“divorce court”) upon constructive notice by publication to the father. As to child support for the parties’ only child, who was then seventeen years old, the divorce court reserved the issue pending personal service of process upon the father. In March 2014, the State of Tennessee, acting on behalf of the mother, filed a petition to set child support. Prior to the petition’s filing, no child support obligation had been set. Following a hearing, the child support magistrate recommended that the trial court consider the reservation of child support to be a prior child support order and find that it could exercise jurisdiction to set child support.