In Re Angela E.

Summary

The Tennessee Supreme Court granted review to resolve a conflict in the Court of Appeals over whether a trial court must make the statutory findings of fact and conclusions of law when terminating the parental rights of a non-opposing parent. Agreeing with the panel below that the 2007 proceeding effected a termination under Tenn. Code Ann. § 36-1-113 rather than a surrender under § 36-1-111, the Court nonetheless held that sections 36-1-113(c) and (k) mandate written findings, supported by clear and convincing evidence, on the grounds for termination and the child's best interests even when the parent consents. Because the trial court's final judgment contained no findings on the grounds for termination, the Court reversed and remanded for an expedited new hearing and a compliant written order, rendering Father's duress claim and related evidentiary challenges moot.