Hoard v. Barrom (Tennessee 2022)

A court is without jurisdiction to modify a support order once a child has emancipated. The state of Tennessee petitioned to modify the father’s support order. The child turned 18 the following month. The trial court modified the order. A year later, the father moved to set aside the order, arguing the trial court had no jurisdiction to modify since the child had turned 18 and graduated from high school before order entry. The court denied the motion to set aside. The father appealed. The appellate court vacated the support order. The trial court was clearly without jurisdiction to enter the order. It was undisputed that the child had reached the age of majority and graduated from high school before order entry and before the retroactive effective date of the modification.