Tennessee Code Annotated

Tenn. Code Ann. § 36-2-403 (2026)

Establishing embryo parentage - Relinquishment of rights and responsibilities

✓ current as of May 2026
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Added by 2013 Tenn. Acts, ch. 309,s 1, eff. 7/1/2013.


Notes of Decisions
Cited in 10 cases (3 in the last 5 years), 2003–2022 · leading case: In Re Baby, 447 S.W.3d 807 (Tenn. 2014).
In Re Baby, 447 S.W.3d 807 (Tenn. 2014). · cites it 2× “§ 36-2-403(d). Because traditional surrogacies do not involve donated embryo transfers, this procedure is not directly applicable to the facts before us; however, these provisions are indicative of a policy geared toward the accommodation of assisted reproductive technology,…”
In re S.Y., 121 S.W.3d 358 (Tenn. Ct. App. 2003). “§ 36-1-113(g)(2) and § 36-2-403. That this Court finds clear and convincing evidence to support the termination of parental rights in that pursuant to T.”
Cedra Deanntre Potts (Taylor) v. Starr Anastasia Potts (2021). · cites it 6× “Following briefing and a hearing, the trial court determined that the defendant was able to establish parentage under Tenn. Code Ann. § 36-2-403 because she met the requirements of the statute, in that she was a party to the written contract consenting to the in vitro…”
Christina Jane Compher v. Dana Janelle Whitefield (Tenn. Ct. App. 2022). · cites it 4× “We explained that, under section 36-2-403, the status as the biological parent does not place an individual in a superior position to that of the defendant who lacked a biological connection to the children.”
Pamela Estelle Harrison v. Shannon Nicole Harrison (Tenn. Ct. App. 2021). · cites it 2× “, Tenn. Code Ann. § 36-2-403 (a) (requiring a “written contract” when establishing embryo parentage prior to embryo transfer).”
In Re Sy, 121 S.W.3d 358 (Tenn. Ct. App. 2003). “§ 36-1-113(g)(2) and § 36-2-403. That this Court finds clear and convincing evidence to support the termination of parental rights in that pursuant to T.”
In Re: Alicia K.A. (Tenn. Ct. App. 2013). · cites it 2× “Compliance with T.C.A. 36-2-403(a)(2)(B) was established (a) by the order entered as the result of the permanency hearing on July 27, 2011, which found that [Mother], who was present at the hearing, was informed that failure to support the child could result in the termination…”
State of Tennessee v. Phyllis McCrary (Tenn. Ct. App. 2006). · cites it 2× “Madison argues that the Juvenile Court erred when it neglected to find that the requirements of the permanency plan were “reasonable and related to remedying the conditions -12- which necessitate foster care placement” as dictated by T.C.A. § 36-2-403(a)(2)(C). However, Mr.…”
In matter of: S.Y., J.Y., & D.Y. (Tenn. Ct. App. 2003). “§ 36-1-113(g)(2) and § 36-2-403. That this Court finds clear and convincing evidence to support the termination of parental rights in that pursuant to T.”
In Re Baby (Tenn. 2014). “§ 36-2-403(d). Because traditional surrogacies do not involve donated embryo transfers, this procedure is not directly applicable to the facts before us; however, these provisions are indicative of a policy geared toward the accommodation of assisted reproductive technology,…”
— Tenn. Code Ann. § 36-2-403(a)(2)(B) — 1 case
In Re: Alicia K.A. (Tenn. Ct. App. 2013). “Compliance with T.C.A. 36-2-403(a)(2)(B) was established (a) by the order entered as the result of the permanency hearing on July 27, 2011, which found that [Mother], who was present at the hearing, was informed that failure to support the child could result in the termination…”
— Tenn. Code Ann. § 36-2-403(a)(2)(C) — 1 case
State of Tennessee v. Phyllis McCrary (Tenn. Ct. App. 2006). “Madison argues that the Juvenile Court erred when it neglected to find that the requirements of the permanency plan were “reasonable and related to remedying the conditions -12- which necessitate foster care placement” as dictated by T.C.A. § 36-2-403(a)(2)(C). However, Mr.…”
— Tenn. Code Ann. § 36-2-403(d) — 3 cases
In Re Baby, 447 S.W.3d 807 (Tenn. 2014). “§ 36-2-403(d). Because traditional surrogacies do not involve donated embryo transfers, this procedure is not directly applicable to the facts before us; however, these provisions are indicative of a policy geared toward the accommodation of assisted reproductive technology,…”
Cedra Deanntre Potts (Taylor) v. Starr Anastasia Potts (2021). “Following briefing and a hearing, the trial court determined that the defendant was able to establish parentage under Tenn. Code Ann. § 36-2-403 because she met the requirements of the statute, in that she was a party to the written contract consenting to the in vitro…”
In Re Baby (Tenn. 2014). “§ 36-2-403(d). Because traditional surrogacies do not involve donated embryo transfers, this procedure is not directly applicable to the facts before us; however, these provisions are indicative of a policy geared toward the accommodation of assisted reproductive technology,…”
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