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Teri Michelle Parker v. Richard Ken Parker

Citation: Not availableDocket: 01A01-9504-CH-00138

Court: Court of Appeals of Tennessee; October 2, 1996; Tennessee; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

In this appellate case, the Wife contested the Chancery Court's decision to award custody of the couple's child to the Husband, alleging that the ruling was tainted by racial prejudice. The trial court's determination included accusations of the Wife's extramarital affair and potential child neglect, supported by a private investigator's evidence and testimony regarding the negative impact of an interracial relationship on the child. Despite the Wife's objections, the trial court found her untruthful and restricted the child's contact with the alleged affair partner. The Wife argued that the custody decision violated the Equal Protection Clause, referencing the Supreme Court's ruling in Palmore v. Sidoti, which prohibits the influence of racial bias in custody determinations. The appellate court conducted a de novo review, presuming the trial court's findings correct unless contradicted by stronger evidence. Ultimately, the appellate court affirmed the custody award to the Husband, citing the child's best interests and the comparative fitness of the parents, while reversing the restriction on the child's contact with the affair partner. The costs of appeal were divided equally between the parties.

Legal Issues Addressed

Best Interests of the Child Standard

Application: The custody decision was evaluated under the best interests of the child standard, considering relative parental fitness.

Reasoning: The trial court's decision favoring Husband for custody aligns with the child’s best interests and is affirmed.

Consideration of Extramarital Affairs in Custody Decisions

Application: The trial court considered the Wife's alleged extramarital affair and its potential impact on child neglect in determining custody.

Reasoning: Evidence suggests that Wife’s extramarital relationship may have led to her neglecting the child, despite her denial.

Custody Determination and Racial Bias

Application: The appellate court examined whether the trial court's custody decision was improperly influenced by alleged racial prejudice.

Reasoning: Wife's appeal argues the ruling stemmed from the trial judge's racial bias, referencing a statement made by the judge that implied prejudiced views regarding interracial relationships.

Impact of Racial Prejudice on Custody Decisions

Application: Citing Palmore v. Sidoti, the court addressed the improper influence of racial bias in custody rulings.

Reasoning: In Palmore v. Sidoti, the Supreme Court addressed the influence of racial prejudice in child custody determinations.

Statement of Evidence and Trial Court Discretion

Application: The trial court's discretion in approving the Statement of Evidence was challenged but ultimately upheld.

Reasoning: The court denied the Wife's request for an evidentiary hearing and an offer of proof, subsequently approving the Husband's Statement of Evidence, which excluded the Wife's proposed statements.