In Re: Knox C., E2016-00768-COA-R3-PT

Child born drug-exposed in Nov. 2014; Father was incarcerated at that time and the Child has remained in foster care since hospital discharge.
DCS filed to terminate parental rights in June 2015; Mother’s rights terminated earlier and are not at issue on appeal; Father’s termination trial occurred Feb. 2016.
Father has been incarcerated since March 25, 2014, serving concurrent convictions that total a 12-year sentence; he expects earliest release in ~2020–2021.
Father has completed prison programs (GED, parenting, anger management, substance classes) but has never met or established a relationship with the Child.
Child resides in a pre-adoptive foster home, is doing well, and has attachments to current foster parents and to an earlier foster family; DCS opposed placement with Father’s proposed caretaker.
Juvenile Court found statutory ground under Tenn. Code Ann. § 36-1-113(g)(6) (parent serving 10+ year sentence while child under 8) proven by clear and convincing evidence and held termination was in the Child’s best interest; this appeal challenges the best-interest determination.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether statutory ground under Tenn. Code Ann. § 36‑1‑113(g)(6) was proven	DCS: Father was sentenced to 12 years while child < 8, satisfying g(6)	Father: did not contest on appeal	Court: g(6) proven by clear and convincing evidence
Whether terminating Father’s parental rights was in Child’s best interest	DCS: Long incarceration, no parent–child relationship, Child in stable pre‑adoptive placement; termination promotes permanence	Father: Parole/early release possibility and rehabilitation in prison support preserving rights and eventual reunification	Court: Considering statutory best‑interest factors and incarceration delay, termination was supported by clear and convincing evidence

Troxel v. Granville, 530 U.S. 57 (parental custody rights are fundamental liberty interests)
Santosky v. Kramer, 455 U.S. 745 (heightened proof—clear and convincing—required in parental termination)
Stanley v. Illinois, 405 U.S. 645 (parental rights as fundamental liberty interests)
Lassiter v. Dep’t of Social Servs., 452 U.S. 18 (due process protections in parental termination proceedings)
Hawk v. Hawk, 855 S.W.2d 573 (Tenn. case discussing State’s parens patriae role)
In re Angela E., 303 S.W.3d 240 (Tenn. 2010) (statutory framework and findings required in termination orders)
In re Bernard T., 319 S.W.3d 586 (clear-and-convincing standard explained for parental termination)
In re Audrey S., 182 S.W.3d 838 (best‑interest analysis and factors are non‑exclusive)
In re Adoption of A.M.H., 215 S.W.3d 793 (appellate review standards in termination cases)
In re M.L.P., 281 S.W.3d 387 (appellate standard for reviewing termination rulings)
In re Dominique L.H., 393 S.W.3d 710 (long incarceration as important factor favoring termination)