IN RE: CONNER C., M2016-01669-COA-R3-JV

Father’s girlfriend filed for emergency temporary custody (Nov. 2015) alleging the children were neglected and that Mother’s household posed danger after an incident in which Father was shot.
Juvenile court granted temporary custody to the girlfriend, then after hearings found by clear and convincing evidence that the children were dependent and neglected and entered an "Adjudicatory Hearing Order" (Feb. 10, 2016).
The juvenile order included temporary custody and specific custody/visitation/conditioning terms (parenting time to maternal grandmother, supervised visitation for Mother, counseling, and household conditions) and set a review hearing for April 13, 2016.
Mother appealed the juvenile order to the circuit court for a de novo review; the circuit court dismissed the appeal, finding the juvenile order was not final because a review hearing remained scheduled.
Mother’s motion to alter or amend was denied; she appealed to the Court of Appeals, which affirmed the circuit court’s dismissal.

Issue	Plaintiff's Argument (Mother)	Defendant's Argument (Appellees)	Held
Whether the juvenile court’s adjudicatory order was a final, appealable dispositional order	The order’s review hearing was a statutory, continuing-jurisdiction matter under § 37-1-103(c), so the juvenile court retained authority and the order was effectively final for appeal	The order was not final because the juvenile court scheduled a further review/dispositional proceeding; therefore appeal to circuit court was premature	The court held the juvenile order was not final and the de novo appeal was properly dismissed
Whether custody provisions in the adjudicatory order amounted to a final dispositional order	Mother argued the custody/visitation terms were dispositive and appealable	Appellees argued the provisions were temporary and the juvenile court signaled further disposition by setting a review	The court treated the provisions as temporary/dispositive-incomplete and emphasized that a pending review indicated the matter was not final

In re Hannah S., 324 S.W.3d 520 (Tenn. Ct. App. 2010) (describing two-phase structure of dependency and neglect proceedings: adjudicatory and dispositional)
In re D.Y.H., 226 S.W.3d 327 (Tenn. 2007) (juvenile court retains jurisdiction to hear future petitions connected to dependency jurisdiction)
In re Estate of Henderson, 121 S.W.3d 643 (Tenn. 2003) (defining final judgment as resolving all issues and leaving nothing else for the trial court to do)
State ex rel. McAllister v. Goode, 968 S.W.2d 834 (Tenn. Ct. App. 1997) (same principle on finality of judgments)