IN RE ELLIOT S.

Court of Appeals of Tennessee·Decided July 22, 2026·No. E2025-00852-COA-R3-PT·Published·Judge Andy D. Bennett

Opinion

07/22/2026 IN THE COURT OF APPEALS OF TENNESSEE AT KNOXVILLE Assigned on Briefs June 2, 2026

IN RE ELLIOT S.

Appeal from the Juvenile Court for Hawkins County No. HJ-24-0816 Amy Skelton, Judge

No. E2025-00852-COA-R3-PT

A mother appeals the termination of her parental rights to her child. Because the Department of Children’s Services declined to defend one ground, we reverse that ground. In all other respects, we affirm.

Tenn. R. App. P. 3 Appeal as of Right; Judgment of the Juvenile Court Reversed in Part and Affirmed in Part

ANDY D. BENNETT, J., delivered the opinion of the Court, in which J. STEVEN STAFFORD, P.J., W.S., and KRISTI M. DAVIS, J., joined.

Cameron L. Hyder, Johnson City, Tennessee, for the appellant, Emily S.

Jonathan Skrmetti, Attorney General and Reporter, Amber L. Barker, Senior Assistant Attorney General, for the appellee, Tennessee Department of Children’s Services.

OPINION

FACTUAL AND PROCEDURAL BACKGROUND

In this case, we determine whether the juvenile court properly terminated Emily S.’s (“Mother’s”) parental rights to her child, Elliot S. (“the child”) (born in 2017).1 In December 2024, the Tennessee Department of Children’s Services (“DCS” or “the Department”) filed a petition to terminate Mother’s parental rights in the Juvenile Court for Hawkins County. In the petition, DCS alleged that the child had been in DCS’s custody since April 2023 and had been adjudicated dependent and neglected in September 2023. The petition also alleged that Mother was incarcerated for all or part of the four months preceding the filing of the petition. As grounds for termination, the petition alleged

1 This appeal concerns only Mother’s rights. The identity of the child’s father is unknown.

abandonment, failure to manifest an ability and willingness to assume custody, and substantial noncompliance with the permanency plans. The petition also alleged that termination was in the child’s best interests.

The trial on the petition was held on March 18, 2025. Those present at the hearing were DCS’s counsel, Mother’s appointed counsel, the child’s guardian ad litem, and two assigned case workers, Sreyroth Weaner and Patty Kline. The child’s foster mother was also present by telephone. Mother, however, was not present at the hearing. Because Mother was not present, her counsel moved for a continuance, which DCS opposed as there was no indication that Mother was prevented from attending the hearing. The guardian ad litem pointed out that Mother was present at the previous hearing when the date and time of the final hearing were set, and Mother’s counsel stated that he had spoken with Mother the day before and that she had said she would be present. Because there was no indication that Mother was prevented from attending the hearing, the court denied the continuance, and the trial proceeded.

The evidence at the trial consisted of the testimony of two witnesses and numerous exhibits. The first witness to testify was Ms. Kline, an in-home worker assigned to the case, who testified that she began working with Mother in January 2025 and had assisted Mother in finding housing and provided Mother with parenting classes. Ms. Kline testified that she initially had difficulty reaching Mother because Mother would not return her calls or messages, but Mother eventually responded. Mother did not have housing when Ms. Kline began working with her, but Mother was employed. Ms. Kline began assisting Mother in finding housing but did not know whether Mother followed through with the assistance provided. As to Mother’s housing, Ms. Kline testified that, to her knowledge, Mother did not have stable housing and that she was staying “in a place in Johnson City where there’s other women. I think it’s one of those places you have to check in.” Ms. Kline testified that she had given Mother parenting classes and was helping Mother prepare to resume visitation and that Mother was receptive to these classes and did well in them. Ms. Kline testified that Mother had completed the classes the previous week. Ms. Kline testified that there had been one visit with the child up to that point; however, she did not know whether Mother had provided any support to the child.

Ms. Weaner, the DCS caseworker assigned to the case, testified next. The child’s father was unknown, and no father was on the child’s birth certificate. Also, the putative father registry returned no results. Ms. Weaner detailed the circumstances surrounding how the child came into DCS’s custody. Mother had left the child with a partner without indicating when she would return, so that partner filed for custody. However, after the partner conducted a DNA test that showed he was not the father, he contacted DCS, which was granted custody in April 2023. Ms. Weaner testified that Mother was incarcerated from August to September 12, 2024, and that Mother had not visited the child in the four months preceding her incarceration. Ms. Weaner also testified that Mother did not pay any support to the child during that period, did not have housing, and did not complete items on her

permanency plan. Ms. Weaner testified that, in her opinion, Mother only began taking steps to assume custody after the petition was filed. Ms. Weaner also testified that the child had various special needs and was bonded with his foster family.2

On April 1, 2025, the juvenile court entered an order terminating Mother’s rights to the child. The court found that Mother was incarcerated from August 14, 2024, to September 12, 2024. The court found that Mother did not visit the child during the four months preceding her incarceration. As a condition of resuming visitation with the child, Mother was required to pass two drug screens, which she did not do, and this prevented Mother from visiting the child. Further, the court found that Mother had failed to pay any support to the child during that period and had exhibited a wanton disregard for the child’s welfare. The court found DCS had also proven the grounds of substantial noncompliance and failure to manifest an ability and willingness to assume custody of the child. The court then analyzed the statutory list of best interest factors and determined that the termination of Mother’s parental rights was in the child’s best interest. Therefore, the court entered an order terminating Mother’s parental rights and appointing DCS as the child’s legal guardian.

Three days later, Mother filed a “motion for rehearing,” asking the court to set aside the judgment and to rehear the matter. The motion asserted that Mother missed the hearing due to excusable neglect. The court held a hearing on the motion on May 7, 2025, and on July 18, 2025, filed an order denying the motion, finding that Mother missed the hearing based on her mistaken belief regarding the start time of the hearing, that Mother was present at the prior hearing at which the date and time of the hearing was set, and that Mother’s “carelessness and nothing more” was not a basis for relief. Therefore, the court denied the motion. Mother appealed and presents the following issues:

1. Whether the Juvenile Court abused its discretion in denying Mother’s Motion for Rehearing where her failure to appear at the termination hearing was the result of mistake, inadvertence, or excusable neglect. 2. Whether terminating Mother’s parental rights in her absence violated her constitutional right to due process. 3. Whether the Department of Children’s Services proved the statutory grounds for termination by clear and convincing evidence. 4. Whether the Department of Children’s Services proved by clear and convincing evidence that termination of Mother’s parental rights was in the child’s best interest.

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IN RE ELLIOT S., (Tenn. Ct. App. 2026).

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