March 2020 | No. E2019-00635-COA-R3-CV (Tenn Ct. App. 2020)

Wilder v. Wilder (Tennessee 2020)

An order that doesn’t adjudicate all of the issues before the court is not final and not ready for appeal. The parents in this case filed competing petitions to modify child support for their three children. The father, the payor, requested a downward modification, arguing his income had decreased. The mother requested an upward modification and asked that support continue beyond the age of majority for the older two children, both of whom the mother alleged were disabled. The trial court entered an order finding the older two children disabled and continuing support beyond the age of their majority. The father appealed. The appellate court dismissed the appeal for a lack of jurisdiction. The trial court had two issues before it: a modification of the ordinary support and a request to continue support beyond the age of majority. The order on appeal only resolved the age of majority issue. The modification of the ordinary support was outstanding. Even though the court continued support beyond the age of majority, the order was not final because the trial court didn’t specify the amount of support.

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