Case Number
E2015-02102-COA-R3-PT
Mother appeals the termination of her parental rights on grounds of abandonment by willful failure to visit and wanton disregard. Because the trial court entered an order during the proceedings that excluded wanton disregard as a ground and this ground was not tried by implied consent, we reverse the trial court's finding of wanton disregard. In addition, the trial court failed to make any finding that Mother's failure to visit the child was willful. Accordingly, we vacate this ground and remand to the trial court for further proceedings.
Originating Judge
Chancellor Jerri S. Bryant
Case Name
In re Addison P.
Date Filed
Dissent or Concur
No
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