In Re Lyric A., 544 S.W.3d 341

Father and Grandmother jointly filed a "Petition for Termination and Adoption" seeking termination of Mother’s parental rights for abandonment and to allow Grandmother to adopt the child while Father would remain a legal parent.
The child primarily lived with Father and Grandmother; Mother had a history of drug use, arrests, and inconsistent contact.
Trial court found Mother abandoned the child by willful failure to visit and willful failure to support, and terminated Mother’s parental rights; Grandmother was allowed to adopt without terminating Father’s rights.
On initial appeal the Court of Appeals remanded for more detailed findings; after revised findings were entered, Mother appealed again.
The Court of Appeals raised standing sua sponte (a jurisdictional issue) and gave the parties an opportunity to brief it; the court found standing dispositive and reviewed the adoption/termination statutory scheme.
The Court held Father and Grandmother lacked statutory standing to seek termination of Mother’s parental rights to permit a third-party adoption without also terminating both parents’ rights (absent limited exceptions), reversed the trial court, and remanded with instructions to dismiss for lack of standing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing to petition to terminate a parent’s rights so a third party may adopt	Father/Grandmother: As co-petitioners, Grandmother qualifies as an "extended family member caring for a related child" under Tenn. Code Ann. § 36-1-113(b)(1), so the joint petition confers standing	Mother: The adoption/termination statutes require termination of both parents’ rights before a third party may adopt, except statutory exceptions; thus petitioners lack standing	Court: Petitioners lack standing; statute unambiguously lists who may file and does not permit a parent plus third party to terminate the other parent’s rights (except narrow exceptions)
Existence of statutory grounds (abandonment) for terminating Mother’s rights	Father/Grandmother: Mother willfully failed to visit and support for more than four consecutive months	Mother: Challenge to sufficiency or applicability of abandonment findings	Court: Did not reach merits because lack of standing is dispositive; prior trial court findings vacated by reversal
Whether termination was in child’s best interest	Father/Grandmother: Termination and adoption by Grandmother would be in child’s best interest	Mother: Best-interest determination improper absent proper petition and jurisdiction	Court: Did not address best-interest due to dispositive standing ruling

Osborn v. Marr, 127 S.W.3d 737 (Tenn. 2004) (standing is a component of subject-matter jurisdiction and may be considered sua sponte on appeal)
Knierim v. Leatherwood, 542 S.W.2d 806 (Tenn. 1976) (standing asks whether a party is properly situated to advance a cause)
Rich v. Tennessee Bd. of Medical Examiners, 350 S.W.3d 919 (Tenn. 2011) (application of expressio unius est exclusio alterius in statutory construction)
State v. Flemming, 19 S.W.3d 195 (Tenn. 2000) (interpretation of clear and unambiguous statutory language)
Simpson v. Frontier Cmty. Credit Union, 810 S.W.2d 147 (Tenn. 1991) (generally courts do not address issues not raised at trial)