Diane C. Hanson v. Gary D. Meadows, M2015-00854-COA-R3-CV

Mother (Diane Hanson) filed a Tennessee petition for an order of protection on May 5, 2014 on behalf of herself and two minor children arising from a May 4, 2014 incident in Tennessee.
At the time, the parties were operating under a Wisconsin parenting plan; Wisconsin had exclusive, continuing jurisdiction over the children under UCCJEA principles.
The Rutherford County Chancery Court issued an ex parte protective order and scheduled an evidentiary hearing, which was continued ~11 months because of related criminal charges against Father (Gary Meadows).
After an April 6, 2015 hearing, the trial court extended the protective order as to Mother (based on Father’s admissions and guilty plea) but dismissed the children’s protection claims, finding no danger to the children and recognizing only temporary emergency jurisdiction regarding them.
By the time of this appeal, custody proceedings and a modified temporary parenting arrangement were pending in Rutherford County; the chancery court had acquired jurisdiction over the parenting plan and current custody issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by dismissing the children’s order of protection	Hanson argued the children needed protection based on the May 4, 2014 incident	Meadows argued Tennessee only had temporary emergency jurisdiction at the time and the children were not endangered	Appeal dismissed as moot because ongoing custody proceedings in the trial court and changed circumstances prevent meaningful appellate relief
Whether appellate court can provide meaningful relief regarding children’s welfare	Hanson sought appellate reversal to secure protection for children	Meadows noted trial court/custody proceedings now control current relief	Mootness bars review; remedies are available in the trial court with present jurisdiction

All. for Native Am. Indian Rights in Tennessee, Inc. v. Nicely, 182 S.W.3d 333 (Tenn. Ct. App. 2005) (justiciability and mootness require an ongoing need for meaningful judicial relief)
McIntyre v. Traughber, 884 S.W.2d 134 (Tenn. Ct. App. 1994) (mootness inquiry centers on whether changed circumstances forestall meaningful relief)