Jonathan Garrett Grace et al. v. Elizabeth Ann Baker Grace

This is a post-divorce parent relocation dispute. After the mother relocated out of state with the child without notice, the father filed a petition objecting to her relocation, a petition for criminal contempt on multiple grounds, and a petition to modify the parenting plan. The mother then filed a petition to approve her relocation and a petition challenging the child support calculations in the court’s November 6, 2023 order. After conducting a best-interest analysis, the court adopted the mother’s proposed parenting plan with modifications that removed the father’s supervision requirement, required the mother to bear transportation costs, and required the mother to give the father notice of the child’s school and extracurricular activities, among other modifications. The trial court also granted the father’s first amended petition for three counts of criminal contempt, imposing a sentence of 30 days, with 10 days suspended, “based upon Mother’s full and complete compliance, during the next five (5) years, with the terms set forth within this judgment.” Father appeals, contending that the trial court abused its discretion by applying an improper legal standard in respect to the notice requirements of the parent relocation statute, Tennessee Code Annotated § 36-6-108. We find that the trial court did not abuse its discretion in conducting a best-interest analysis, affirm the trial court’s determination that the relocation was in the best interest of the child, and affirm the trial court’s adoption of the mother’s parenting plan with modifications.