In the Matter of Oliver Ray Valentine, Jr.

Summary

The Tennessee Supreme Court reversed a juvenile court's termination of Chanya Wallace's parental rights to her son Oliver. Holding that a juvenile court referee may serve as special judge under Tenn. Code Ann. § 17-2-118(f)(2) without offending Article VI, § 4's election requirement, and that no procedural error attended the appointment (the general-authority objection having been waived and termination proceedings falling within 'matters related' to the referee's duties), the court then found neither termination ground — substantial noncompliance with the permanency plans nor persistent conditions — proven by clear and convincing evidence, pretermitting the best-interest inquiry. It reversed and remanded, leaving custody unchanged with the Shelby County Juvenile Court and permitting future termination petitions. No separate opinions were issued.