In Re Halley M., M2016-01596-COA-R3-PT

Petitioners (maternal uncle and aunt) filed to terminate parental rights and adopt the child on November 13, 2012; the child had lived with them for over two years.
Respondent was listed on the birth certificate and signed a Voluntary Acknowledgement of Paternity (VAP); later private and court-ordered DNA tests showed Respondent had a zero percent chance of paternity.
Trial scheduling: the court initially set a three-day trial (at respondent's request); the judge later died and the trial was reset; the guardian ad litem (GAL) sought DNA testing and later filed to rescind the VAP, prompting continuances.
On March 25, 2015, Respondent moved to dismiss the adoption petition for failure to complete the adoption within one year under Tenn. Code Ann. § 36-1-119(d); petitioners filed proof of inquiry to the putative father registry that same day.
The trial court dismissed the petition on May 26, 2015 under § 36-1-119(d) for lack of good cause; Petitioners appealed.
The Court of Appeals vacated the dismissal, holding petitioners demonstrated good cause because delays were not their fault (scheduling, judge death, GAL continuances, and DNA testing) and reinstated the petition.

Issue	Plaintiff's Argument (Petitioners)	Defendant's Argument (Respondent)	Held
Whether dismissal under Tenn. Code Ann. § 36-1-119(d) was proper for failure to enter a final order within one year	Petitioners argued they showed good cause: they timely sought a trial date, did not seek continuances, and delays were caused by judge death, GAL actions, scheduling needs (three-day trial), and DNA testing	Respondent argued the petition must be dismissed because the adoption was not completed within one year and alleged procedural deficiencies (e.g., putative father registry inquiry)	Court of Appeals reversed: petitioners showed good cause; vacated dismissal, reinstated the petition, and remanded for further proceedings

Clements v. Morgan, 296 S.W.2d 874 (Tenn. 1956) (adoption statutes must be strictly complied with; prior case finding lack of good cause where petition languished)
Austin v. State, 222 S.W.3d 354 (Tenn. 2007) (statutory construction reviewed de novo; courts determine legislative intent from statutory language)