State ex. re. Williams v. Woods (Tennessee 2017)

Child support is due to a child’s primary caregiver even if that person is not a parent. However, the caregiver must request support and be a party to the action. In this case, mother petitioned the court for child support as the child’s primary caregiver even though the child lived his step grandparent during the school week. The father appealed the award in that all the retroactive support went to mother, even for the time the child lived with his step grandfather. The step grandfather testified he considered the parents to be the child’s primary decision makers. The court found that step grandfather had not requested support, was not a party, and upheld the award to mother.