Travis Daniel Freeman v. Wendy Y. Freeman, 579 S.W.3d 1

Parents divorced in 2013; final permanent parenting plan named mother primary residential parent and gave father limited supervised Saturday visitation, with provision allowing father to seek unsupervised/expanded time later.
Father filed a petition to modify on Nov. 7, 2014 and attached a proposed permanent parenting plan as required by Tenn. Code Ann. § 36-6-405(a).
The court gradually expanded father’s parenting time by orders entered Dec. 29, 2015 and Aug. 11, 2016, each containing language suggesting review after a year; the court later treated those orders as final judgments.
On Jan. 31, 2017 father filed a motion seeking further expansion and/or primary residential status but did not attach a new proposed parenting plan to that motion.
Trial court entered a new permanent parenting plan on Sept. 27, 2017 granting father additional co-parenting time but leaving mother as primary; mother appealed arguing lack of subject-matter jurisdiction because father failed to attach a proposed plan to the 2017 motion.
The Court of Appeals concluded father was statutorily required to file a proposed plan when invoking jurisdiction after a final judgment but that his failure to attach one did not strip the trial court of jurisdiction; it affirmed the judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether failure to attach a proposed permanent parenting plan to a post-judgment petition/motion divests the trial court of subject-matter jurisdiction to modify a permanent parenting plan	Freeman (mother) contends father’s Jan. 31, 2017 motion did not invoke the court’s jurisdiction because he failed to attach a new proposed parenting plan as required by § 36-6-405(a) after prior final judgments	Father (appellee) contends his earlier compliant petition and subsequent motion were sufficient to invoke jurisdiction and that partial noncompliance does not mandate dismissal	Court held father was required to file a proposed plan when invoking jurisdiction after final judgments, but his failure to attach one did not render his attempt to invoke jurisdiction ineffective; trial court had jurisdiction and its order was affirmed

Redwing v. Catholic Bishop for Diocese of Memphis, 363 S.W.3d 436 (Tenn. 2012) (standards for reviewing subject-matter jurisdiction and related principles)
Creech v. Addington, 281 S.W.3d 363 (Tenn. 2009) (trial court may revise nonfinal domestic orders; finality affects need to re-invoke jurisdiction)
Hoalcraft v. Smithson, 19 S.W.3d 822 (Tenn. Ct. App. 1999) (trial court lacks authority to indefinitely delay finality of parenting plan)