Tennessee Code Annotated

Tenn. Code Ann. § 36-2-303 (2026)

Custody with mother absent an order of custody

✓ current as of May 2026
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Absent an order of custody to the contrary, custody of a child born out of wedlock is with the mother.

Acts 1997, ch. 477, § 1.


Notes of Decisions
Cited in 25 cases (4 in the last 5 years), 2001–2025 · leading case: In Re Audrey S., 182 S.W.3d 838 (Tenn. Ct. App. 2005).
In Re Audrey S., 182 S.W.3d 838 (Tenn. Ct. App. 2005). · cites it 3× “Tenn.Code Ann. § 36-2-303 (2001); Baskette v.”
In re C.K.G., 173 S.W.3d 714 (Tenn. 2005). · cites it 2× “Tenn.Code Ann. §§ 36-2-303, 36-2-305(b)(l)(B) (2001), whereas references to “father” include such phrases as “a man claiming to be the child’s father,” Tenn.”
In Re Ckg, 173 S.W.3d 714 (Tenn. 2005). · cites it 2× “Tenn.Code Ann. §§ 36-2-303, 36-2-305(b)(1)(B) (2001), whereas references to "father" include such phrases as "a man claiming to be the child's father," Tenn.”
Hodson v. Griffin, 210 S.W.3d 568 (Tenn. Ct. App. 2006). · cites it 2× “T.C.A. § 36-2-303 provides that "[a]bsent an order of custody to the contrary, custody of a child bom out of wedlock is with the mother.”
In Re: D.A.J. (Tenn. Ct. App. 2005). · cites it 8× “1 Tenn. Code Ann. § 36-2-303 provides that “[a]bsent an order of custody to the contrary, custody of a child born out of wedlock is with the mother.”
Tamara Reece Milton v. Randall v. Harness, Jr. (Tenn. Ct. App. 2017). · cites it 4× “Shortly thereafter, Mother filed a motion to set aside the ex parte injunction on grounds that it had been invalidly issued in that she was the sole legal and physical custodial parent of Child pursuant to Tennessee Code Annotated section 36-2-303, and was not required to…”
In Re Elijah R. (Tenn. Ct. App. 2021). · cites it 4× “” Tenn. Code Ann. § 36-2-303 . This statute provides “the default rules for child custody involving unwed parents.”
In Re Piper H. (Tenn. Ct. App. 2016). · cites it 2× “8 See Tenn. Code Ann. § 36-2-303 (2014) (“Absent an order of 8 Those factors require the court to consider the child’s relationship with each parent (factor 1), each parent’s capacity to perform parenting responsibilities (factor 2), the degree to which each parent has been the…”
In Re Cannon H. (Tenn. Ct. App. 2016). · cites it 2× “10 See Tenn. Code Ann. § 36-2-303 (2014) (“Absent an order of custody to the contrary, custody of a child born out of wedlock is with the mother.”
In Re Ashton V. (Tenn. Ct. App. 2017). · cites it 2× “Tenn. Code Ann. § 36-2-303 (2014). In January 2015, in response to Father’s request for specific parenting time, the Juvenile Court1 for Sumner County, Tennessee, entered an order naming Mother primary residential parent and granting Father parenting time every other weekend.”
Takesha Curtiss Nelvis v. Lafayette Baptist, Jr. (Tenn. Ct. App. 2019). · cites it 2× “Said child resided at birth with her mother who, pursuant to Tennessee Code Annotated, Section 36-2-303, had custody. No mention was made by either parent to there being any visitation prior to August, 2017.”
In Re: Braelyn S. (Tenn. Ct. App. 2020). · cites it 2× “See generally Tenn. Code Ann. § 36-2-303 (“Absent an order of custody to the contrary, custody of a child born out of wedlock is with the mother.”
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