Modification of Grandparent Visitation in Tennessee: Lovlace v. Copley

Modification of Grandparent Visitation in Tennessee: Lovlace v. Copley « Herston on Tennessee Family Law:

Facts: In their divorce, Mother was designated the primary residential parent of Child and Father was awarded supervised visitation. Eventually, Mother married Stepfather. The paternal grandparents petitioned for grandparent visitation, which ultimately led to an agreed order providing for grandparent visitation. Several years later, Father consented to Stepfather’s adoption of Child. The order of adoption specifically stated it did not alter or modify the grandparent visitation rights established in the previous agreed order. Later, the 
grandparents petitioned to modify the prior agreed order to allow additional visitation with Child. Mother and Stepfather counter-petitioned to terminate the grandparent visitation in its entirety. After a hearing, the trial court modified the prior agreed order only to mandate specific times for the grandparent visitation. The trial court denied the grandparents’ request for more visitation and denied the Mother and Stepfather’s request to terminate grandparent visitation entirely. The grandparents appealed.

On Appeal: The Court of Appeals, in three separate opinions, vacated the trial court’s judgment.


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