IN RE NATHANIEL D.

Although I agree that Father did sufficiently raise in his answer the affirmative defense of lack of willfulness regarding the statutory ground of failure to pay child support, I respectfully dissent from the majority’s holding and instead believe that Father’s failure to pay support was willful according to Tennessee law. As the majority points out, the proof was “undisputed that Father paid no child support during the relevant four-month period despite having the ability to pay.” Father argued that such failure was not willful because he had relied on the January 2021 agreed order of paternity entered by the juvenile court, which stated that “any and all issues related to . . . child support are reserved and referred to the Custody Magistrate,” and the fact that no further orders concerning child support had been entered.