In Re: Taylor B. W., 397 S.W.3d 105

Mother and Father divorced in 2002 and entered a parenting plan for Taylor and Ashley.
In 2002 Mother injected Father with a euthanizing chemical; she pleaded guilty to attempted second degree murder and received a 12-year sentence.
In 2004 the parenting plan was amended to provide Grandmother visitation and time for Mother in prison, with a plan to return to the original arrangement after Mother’s release under Grandmother supervision.
During incarceration, Father began a relationship with Stepmother, who later moved to Tennessee and married Father in 2009; the children stopped visiting Mother in prison.
In 2009 Father and Stepmother sought termination of Mother’s parental rights and Stepmother’s adoption; Grandmother’s visitation case was consolidated with the termination case.
Trial court initially terminated but later amended order denying termination; Court of Appeals reinstated the termination finding; Tennessee Supreme Court reviewed the State’s best-interests standard.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is termination in the children's best interests?	Father/Stepmother contended best interests favored termination.	Mother contended termination was not in best interests.	No; termination not proven by clear and convincing evidence
Does res judicata or collateral estoppel bar relitigation?	Father/Stepmother argued prior order precluded re-litigation.	Mother argued privity/estoppel barred relitigation.	Inapplicable; different actions and issues; res judicata/collateral estoppel do not apply
What standard governs review of trial court findings in termination cases?	Findings should support termination by clear and convincing evidence.	Court should defer to trial findings as factual under proper standard.	We review de novo with presumption of correctness for findings; apply clear and convincing standard to best interests
Did the 2004 parenting-plan modification have preclusive effect on best interests?	Modification affected future best interests.	Modification precluded change in best interests.	No preclusive effect; could be considered but did not compel termination
Should constitutional substantial risk of harm be addressed here?	Constitutional issue requires finding substantial risk before termination.	Not necessary to address constitutional questions unless raised below.	Declined to address; not necessary to resolve this case

In re Bernard T., 319 S.W.3d 586 (Tenn. 2010) (clear-and-convincing standard for best-interests review in parental termination)
In re Valentine, 79 S.W.3d 539 (Tenn. 2002) (definition of clear and convincing evidence; standard of review guidance)
Jones v. Garrett, 92 S.W.3d 835 (Tenn. 2002) (heightened standard applied to factual findings)
Clark v. Sputniks, LLC, 368 S.W.3d 431 (Tenn. 2012) (collateral estoppel analysis for best-interest determinations)
Mullins v. State, 294 S.W.3d 529 (Tenn. 2009) (collateral estoppel applicability and related principles)
Osborn v. Marr, 127 S.W.3d 737 (Tenn. 2004) (standards for res judicata and related doctrines in family matters)