In Re Brady R.

CourtCourt of Appeals of Tennessee
DecidedApril 7, 2026
DocketM2025-00691-COA-R3-PT
StatusPublished
AuthorJudge W. Neal McBrayer

This text of In Re Brady R. (In Re Brady R.) is published on Counsel Stack Legal Research, covering Court of Appeals of Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re Brady R., (Tenn. Ct. App. 2026).

Opinion

04/07/2026 IN THE COURT OF APPEALS OF TENNESSEE AT NASHVILLE January 8, 2026 Session

IN RE BRADY R.

Appeal from the Chancery Court for Putnam County No. 2023-6-A Ronald Thurman, Judge ___________________________________

No. M2025-00691-COA-R3-PT ___________________________________

This appeal arises from a petition to terminate the parental rights of a father for the purposes of adoption. The petitioners, the child’s stepfather and mother, alleged that the father abandoned the child both by failing to visit and by failing to support. When father failed to participate in discovery, the petitioners moved for a default as a sanction. After granting the requested default and holding an evidentiary hearing, the trial court concluded that there was clear and convincing evidence of abandonment and that termination of father’s parental rights was in the child’s best interest. Finding no reversible error, we affirm the termination of parental rights.

Tenn. R. App. P. 3 Appeal as of Right; Judgment of the Chancery Court Affirmed

W. NEAL MCBRAYER, J., delivered the opinion of the court, in which ANDY BENNETT and JEFFREY USMAN, JJ., joined.

M. Tyler Daniels, Cookeville, Tennessee, for the appellant, Coby R.

Michael Weston, Cookeville, Tennessee, for the appellees, Samantha P. and Tristan P.

OPINION

I.

A.

By the time Tristan P. (“Stepfather”) petitioned to terminate the parental rights of Coby R. (“Father”) to Brady R. and for adoption in 2023, Father had not visited with the child in over twenty months. He had not provided support for the child for even longer. The petition also alleged that Father was incarcerated and that his anticipated release date was unknown.

Stepfather had cared for the child along with the child’s mother, Samantha P. (“Mother”), for several years. They had married fifteen months before filing the petition, which Mother joined in support of Stepfather’s request to adopt. See Tenn. Code Ann. § 36-1-115(c) (Supp. 2025) (requiring the petitioner’s spouse to join a petition for adoption).

Father filed a handwritten response to the petition, and the court appointed him counsel. The case sat dormant for some time, and then, at a status conference, the court granted Father’s counsel permission to withdraw and appointed substitute counsel. Later, Stepfather and Mother served Father’s substitute counsel with interrogatories and requests for production of documents. When Father failed to respond to the discovery after several months, Stepfather and Mother moved to compel responses. The court entered an agreed order that required Father to respond to the discovery within twenty days of the entry of the order. The agreed order included a finding that Father had not “responded to his counsel of record after his counsel of record attempted to communicate with him.”

Despite the order compelling responses to discovery, Father still failed to respond, leading Stepfather and Mother to move for sanctions. Their motion requested, among other sanctions, that Father’s response to the termination petition be stricken and that a default be entered.

By the time the motion for sanctions was heard, the discovery sent to Father had been outstanding for nearly ten months. Father did not appear for the hearing, but his counsel did. When the court asked counsel for his position on the request for sanctions, counsel responded that he “d[idn’t] really have a leg to stand on.” Counsel also recounted his unsuccessful efforts to communicate with his client. Ultimately, the court struck Father’s response and granted the requested default.

At the hearing on the petition to terminate, only Stepfather and Mother testified. As for Father’s contact with the child, Mother explained that she informally agreed with Father that he would have the child on Wednesday and Saturday nights. But, according to Mother, Father did not regularly exercise his visitation. Although the agreed upon pick-up time was 7:00, “[s]ometimes he wouldn’t come until 9,” and “[s]ometimes he wouldn’t come at all.” When Father exercised his visitation, he typically did so with his mother, with whom he lived at the time.

Mother married Stepfather in 2020, just over nine years after the child’s birth. Following her marriage, she attempted to abide by her agreed visitation schedule with Father, but that effort ended in May 2021. One Saturday that month, a day she intended to drop the child off with Father, she received a text message from Father’s mother alerting 2 Mother that Father had been arrested for a traffic violation. When Stepfather and Mother called the clerk’s office the following Monday to find out the circumstances behind the arrest, Mother learned that Father “had been pulled over and they found needles, scales and straws in his vehicle.” At that point, Stepfather and Mother decided not to permit Father further visitation until he could provide a “clean” drug test.

The following month, for Father’s Day, Mother and Stepfather decided to permit Father to speak with the child by phone. Mother testified that Father “sounded very under the influence,” so the child was not allowed to speak to Father. Stepfather recalled the circumstances differently. His recollection was that, at some point, Father called to speak with the child, but Stepfather and Mother refused because Father “sounded inebriated.” Later, they allowed the child to call, and the child wished Father a happy Father’s Day. Mother and Stepfather agreed that Father’s Day 2021 was the last contact Father had with the child.

Father’s record of financial support for the child was no better. Despite being court ordered to pay support of just under $500 per month, Mother testified Father last paid child support in March 2021.

The proof showed that Father’s was incarcerated again in June 2022. He ultimately pleaded guilty to aggravated assault with a deadly weapon, a Class C felony, and was sentenced to three years, with one year to be served in jail and the remainder to be served on supervised probation. Id. § 39-13-102(a)(1)(A)(iii), (e)(1)(A)(ii) (Supp. 2021). When the hearing on the termination petition took place, although Father was no longer incarcerated, he was facing an allegation that he had violated the terms of his probation.1

Based on the evidence offered by Stepfather and Mother, the court terminated Father’s parental rights and granted Stepfather’s petition to adopt the child. The court concluded that there was clear and convincing evidence of abandonment by an incarcerated parent both by failure to visit and failure to support. Id. §§ 36-1-113(c)(1), (g)(1), -102(1)(A)(iv) (2021). In its judgment, which incorporated by reference the court’s oral ruling, the court found that Father did not visit or provide support “in the relevant four (4) month period of non-incarceration immediately preceding the filing of the verified petition to terminate parental rights,” referencing a specific exhibit introduced into evidence at the hearing. The court also concluded that there was clear and convincing evidence that termination of Father’s parental rights was in child’s best interest. Id. § 36- 1-113(c)(2).

1 The evidence showed that Father had a positive urine drug screen for fentanyl in March 2024. When Father reported for another drug screen almost a month later, he attempted to falsify the results. Father later pleaded guilty to falsification of the results of a drug test. See Tenn. Code Ann. § 39-17- 437(a)(1) (2025). 3 B.

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Bluebook (online)
In Re Brady R., Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-brady-r-tennctapp-2026.