In Re Justin N. et al.

Case Number
E2022-01603-COA-R3-PT

Father appeals the trial court’s termination of his parental rights to two minor children. The trial court found as grounds for termination: (1) abandonment by failure to support, (2) abandonment by failure to visit, and (3) a failure to manifest an ability and willingness to parent. The trial court also found that termination was in the children’s best interests. We affirm as to the finding of abandonment by failure to support and failure to visit. Because the trial court’s order does not contain sufficient findings of fact, we vacate the trial court’s
findings that the father failed to manifest a willingness and ability to parent. We also reverse the trial court’s use of the outdated best interest factors and vacate the trial court’s finding that termination was in the children’s best interests.

Authoring Judge
Judge J. Steven Stafford
Originating Judge
Judge J. Michael Sharp
Date Filed
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