State, ex rel., Schrita O. v. Robert T., Concur in part and Dissent in part, W2017-00073-COA-R3-JV

Juvenile court entered a judgment awarding retroactive child support; in its calculation the court credited Mother with 285 days of parenting time and Father with 80 days.
Father appealed, arguing the juvenile court erred by crediting Mother with 285 days of parenting time for purposes of calculating retroactive child support.
The State (on behalf of Mother/child) had expressly asked the trial court to use the standard visitation credit (80 days) when computing support.
The Court of Appeals majority vacated the trial court’s retroactive support calculation and remanded so child support be recalculated based on the actual number of days Father exercised parenting time.
Judge Frank G. Clement, Jr., concurred in part but dissented from the remand as to retroactive support, arguing the issue of reducing Father’s 80-day credit was waived because neither party sought less than 80 days and the State had affirmatively requested the 80-day credit.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the juvenile court erred in calculating retroactive child support by crediting Mother with 285 days of parenting time	Father: trial court erred; support should reflect actual days Father exercised parenting time	State/Mother: trial court should use standard visitation credit (80 days) and had requested that credit	Majority: vacated retroactive support calculation and remanded to recalculate support based on actual days Father exercised parenting time; Concurrence: remand was improper because issue was waived (State requested 80-day credit)

Bing v. Baptist Mem’l Hosp.-Union City, 937 S.W.2d 922 (Tenn. Ct. App. 1996) (appellate courts may treat issues not raised on appeal as waived)
Champion v. CLC of Dyersburg, LLC, 359 S.W.3d 161 (Tenn. Ct. App. 2011) (issues not raised in the statement of issues may be considered waived)
Regions Fin. Corp. v. Marsh USA, Inc., 310 S.W.3d 382 (Tenn. Ct. App. 2009) (same principle regarding waiver of unraised issues)
Alexander v. Armentrout, 24 S.W.3d 267 (Tenn. 2000) (doctrine that issues not preserved may not be considered on appeal)
Johnson v. Hopkins, 432 S.W.3d 840 (Tenn. 2013) (subject-matter jurisdiction can be raised by court sua sponte at any time)
Osborn v. Marr, 127 S.W.3d 737 (Tenn. 2004) (standing is a component of subject-matter jurisdiction and may be considered even if not raised below)
Simpson v. Frontier Cmty. Credit Union, 810 S.W.2d 147 (Tenn. 1991) (generally courts will not address issues not raised in the trial court)