In Re Amiyah W. Et Al.

This is a termination of parental rights case.  The trial court terminated Mother’s parental rights to the two minor children on the grounds of: (1) abandonment by failure to visit; (2) abandonment by failure to establish a suitable home; (3) substantial noncompliance with the permanency plans; (4) severe child abuse; (5) persistence of the conditions that led to the children’s removal; and (6) failure to manifest an ability and willingness to assume custody.  The trial court also determined that termination of Mother’s parental rights is in the children’s best interests.  As an initial matter, Mother asserts that, having surrendered her parental rights at the outset of the hearing (she later rescinded her surrender), the trial court was required to continue the hearing under Tennessee Code Annotated section 36-1-112. We hold that Tennessee Code Annotated section 36-1-112 does not require a trial court to either continue or delay a contested termination hearing when a parent surrenders his or her parental rights before or during the hearing.  We reverse the trial court’s termination of Mother’s parental rights on the ground of severe child abuse.  We affirm the trial court’s termination of Mother’s parental rights on all remaining grounds and on its finding that termination of Mother’s parental rights is in the children’s best interests.