Modifying the Parenting Plan: Failure to Designate Holiday Parenting Time, Prohibition on Obtaining Passports and International Travel Reversed in Post-Divorce Litigation.

  • Published In: Tennessee Bar Journal, 2026, v. 62, n. 1. P. 37 1 of 3

  • Database: Academic Search Ultimate 2 of 3

  • Authored By: Moses, Marlene Eskind; Tillett, Ansley Owens 3 of 3

Abstract

The article discusses a recent ruling by the Tennessee Court of Appeals in the case of Boatman v. Odziana, which addresses modifications to a parenting plan following a divorce. The court upheld the trial court's decision to grant equal (50/50) parenting time despite significant family dysfunction and a poor parent-child relationship, emphasizing the necessity of including holiday parenting time in residential schedules. Additionally, the court reversed the trial court's prohibition on obtaining passports and international travel for the children, stating that such restrictions require evidence of a credible risk of abduction, which was not demonstrated. The ruling highlights the importance of credibility assessments in custody cases and the trial court's discretion in making parenting plan decisions. [Extracted from the article]

Additional Information

  • Source:Tennessee Bar Journal. 2026/01, Vol. 62, Issue 1, p37
  • Document Type:Article
  • Subject Area:Sociology
  • Publication Date:2026
  • ISSN:0497-2325
  • Accession Number:191318565
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