Andrew K. Armbrister v. Melissa H. Armbrister

OPINION

in which GARY R. WADE, C.J., and JANICE M. HOLDER, WILLIAM C. KOCH, JR., and SHARON G. LEE, JJ„ joined.

The issue in this post-divorce proceeding is whether a parent seeking to modify a residential parenting schedule in a permanent parenting plan must prove that an alleged material change in circumstances could not reasonably have been anticipated when the residential parenting schedule was originally established. We hold that Tennessee Code Annotated section 36-6-101(a)(2)(C) (2010), enacted in 2004, abrogated any prior Tennessee decision that could have been read as requiring such…