In Re Estate of James Keith Owen, M2017-00656-COA-R3-CV

James Keith Owen died July 15, 2015; his will was probated and the estate closed February 25, 2016.
On July 14, 2016, James Lee Owen (the decedent's father) petitioned to reopen the estate, claiming to be a creditor and asserting he never received actual notice to file claims under Tenn. Code Ann. § 30-2-306(d).
James Lee Owen filed a verified claim for $155,000, alleging a cash loan to the decedent to build speculative houses; the executrix filed an exception arguing lack of documentation and that the claim was time-barred.
At a hearing, the trial court found no proof of a loan or any basis for equitable remedies (constructive, resulting, or express trust) and concluded the four-month probate-claim period applied and was not timely met.
The trial court dismissed the claim; on appeal Owen challenged the trial court’s interpretation of Tenn. Code Ann. § 30-2-306(d) (whether a creditor must provide proof of debt before personal representative must mail published notice).
The Court of Appeals affirmed, holding the notice issue moot because the trial court found the claim without merit.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Tenn. Code Ann. § 30-2-306(d) requires a creditor to provide proof of a contract/debt before the personal representative must mail published notice	Owen: PR must mail notice only if creditor provides proof or sufficient information establishing a debt	Estate: Notice not required here because no reasonable basis to know of a valid debt; published notice to creditors was sufficient	Moot — Court declined to decide statute interpretation because trial court found no proven debt; judgment affirming dismissal upheld

Bowden v. Ward, 27 S.W.3d 913 (Tenn. 2000) (standard of review for trial-court findings of fact and conclusions of law)
Alliance for Native Am. Indian Rights in Tenn., Inc. v. Nicely, 182 S.W.3d 333 (Tenn. Ct. App. 2005) (mootness is a question of law)