Tennessee Code Annotated
Tenn. Code Ann. § 36-5-2205 (2026)
Continuing, exclusive jurisdiction to modify child support order
✓ current as of May 2026
- (a) A tribunal of this state that has issued a child support order consistent with the law of this state has and shall exercise continuing, exclusive jurisdiction to modify its child support order if the order is the controlling order and:
- (1) At the time of the filing of a request for modification this state is the residence of the obligor, the individual obligee, or the child for whose benefit the support order is issued; or
- (2) Even if this state is not the residence of the obligor, the individual obligee, or the child for whose benefit the support order is issued, the parties consent in a record or in open court that the tribunal of this state may continue to exercise jurisdiction to modify its order.
- (b) A tribunal of this state that has issued a child support order consistent with the law of this state may not exercise continuing, exclusive jurisdiction to modify the order if:
- (1) All of the parties who are individuals file consent in a record with the tribunal of this state that a tribunal of another state that has jurisdiction over at least one of the parties who is an individual or that is located in the state of residence of the child may modify the order and assume continuing, exclusive jurisdiction; or
- (2) Its order is not the controlling order.
- (c) If a tribunal of another state has issued a child support order pursuant to the Uniform Interstate Family Support Act or a law substantially similar to that Act which modifies a child support order of a tribunal of this state, tribunals of this state shall recognize the continuing, exclusive jurisdiction of the tribunal of the other state.
- (d) A tribunal of this state that lacks continuing, exclusive jurisdiction to modify a child support order may serve as an initiating tribunal to request a tribunal of another state to modify a support order issued in that state.
- (e) A temporary support order issued ex parte or pending resolution of a jurisdictional conflict does not create continuing, exclusive jurisdiction in the issuing tribunal.
Acts 2010, ch. 901, § 1.
Notes of Decisions
Cited in 19
cases, 2001–2018 · leading case: LeTellier v. LeTellier, 40 S.W.3d 490 (Tenn. 2001).
LeTellier v. LeTellier, 40 S.W.3d 490 (Tenn. 2001). “[1] Tenn.Code Ann. § 36-5-2205(a)(1). The District of Columbia "no longer ha[d] an appropriate nexus with the parties or the child to justify exercise of jurisdiction to modify.”
Michael Todd Highfill v. Heather (Highfill) Moody (Tenn. Ct. App. 2010). “Tenn. Code Ann. § 36-5-2205 ; see also Young v.”
Letellier v. Letellier, 40 S.W.3d 490 (Tenn. 2001). “§ 36-5-2205 cmt. 2 B. Section 2611(a): Tennessee’s Jurisdiction to Modify Out-of-State Orders Section 36-5-2611(a) of UIFSA confers subject matter jurisdiction upon Tennessee courts to modify child support orders issued by other states.”
Aragorn LaFayette Earls v. Jill Andrea Mendoza (Tenn. Ct. App. 2011). “T.C.A. § 36-5-2205, cmt. (2005). Thus, the issuing tribunal retains exclusive jurisdiction to modify its order unless the narrowly defined exceptions apply.”
Jessica Hooper McQuade (now Burnett) v. Michael Vincent McQuade (Tenn. Ct. App. 2010). “T.C.A. § 36-5-2205, cmt. (2005). Thus, the issuing tribunal retains exclusive jurisdiction to modify its order unless the narrowly defined exceptions apply.”
Christina Cliburn v. Paul David Bergeron (Tenn. Ct. App. 2002). “See Tenn. Code Ann §§ 36-5-2205 & 2206. In particular, Tenn.”
Deborah Vivien v. Keith W. Campbell (Tenn. Ct. App. 2011). “T.C.A. § 36-5-2205, cmt. (2005). Therefore, the comments state that the issuing tribunal retains exclusive jurisdiction to modify its order unless the narrowly defined exceptions apply.”
Geret Jesse Johnston v. Susan Harwell (Tenn. Ct. App. 2013). “Hawai’i no longer has “continuing, exclusive jurisdiction over a child support order” under Tenn. Code Ann. § 36-5-2205 (a)(1) because Mr.”
State, ex rel., Shem Peter Malmquist v. Danielle Nicolosi Malmquist (Tenn. Ct. App. 2018). “2 Tenn. Code Ann. § 36-5-2205 (a)(1) (2017).”
Dawn Eileen Shannon v. Thomas Rex Shannon (Tenn. Ct. App. 2005). “Shannon pursuant to Tennessee Code Annotated § 36-5-2201 and jurisdiction to modify the order of support under Tennessee Code Annotated § 36-5-2205. Mr. Shannon, on the other hand, asserts Tennessee Code Annotated § 36-5- 2201 and § 36-5-2205 are inapplicable in this case.”
State of Tennessee, ex rel. Commonwealth of Kentucky v. Steven Farmer (Tenn. Ct. App. 2010). “8 T.C.A. § 36-5-2205 cmts. They further explain: “The basic principle of the Act [UIFSA] is that throughout the process the controlling order remains the order of the issuing State, and that responding States only assist in the enforcement of that order.”
Melody Young v. Donald Gregory Godfrey (Tenn. Ct. App. 2008). “§ 36-5-2205 (d) (“A tribunal of this state shall recognize the continuing, exclusive jurisdiction of a tribunal of another state which has issued a child-support order pursuant to parts 20-29 or a law substantially similar to parts 20-29.”
— Tenn. Code Ann. § 36-5-2205(a) — 1 case
Jennifer Ferrari-Bullock v. Justin Randall (Tenn. Ct. App. 2012).
— Tenn. Code Ann. § 36-5-2205(a)(1) — 5 cases
LeTellier v. LeTellier, 40 S.W.3d 490 (Tenn. 2001). “[1] Tenn.Code Ann. § 36-5-2205(a)(1). The District of Columbia "no longer ha[d] an appropriate nexus with the parties or the child to justify exercise of jurisdiction to modify.”
Letellier v. Letellier, 40 S.W.3d 490 (Tenn. 2001). “§ 36-5-2205 cmt. 2 B. Section 2611(a): Tennessee’s Jurisdiction to Modify Out-of-State Orders Section 36-5-2611(a) of UIFSA confers subject matter jurisdiction upon Tennessee courts to modify child support orders issued by other states.”
Aragorn LaFayette Earls v. Jill Andrea Mendoza (Tenn. Ct. App. 2011). “T.C.A. § 36-5-2205, cmt. (2005). Thus, the issuing tribunal retains exclusive jurisdiction to modify its order unless the narrowly defined exceptions apply.”
Jessica Hooper McQuade (now Burnett) v. Michael Vincent McQuade (Tenn. Ct. App. 2010). “T.C.A. § 36-5-2205, cmt. (2005). Thus, the issuing tribunal retains exclusive jurisdiction to modify its order unless the narrowly defined exceptions apply.”
Deborah Vivien v. Keith W. Campbell (Tenn. Ct. App. 2011). “T.C.A. § 36-5-2205, cmt. (2005). Therefore, the comments state that the issuing tribunal retains exclusive jurisdiction to modify its order unless the narrowly defined exceptions apply.”
— Tenn. Code Ann. § 36-5-2205(a)(2) — 1 case
Aragorn LaFayette Earls v. Jill Andrea Mendoza (Tenn. Ct. App. 2011). “T.C.A. § 36-5-2205, cmt. (2005). Thus, the issuing tribunal retains exclusive jurisdiction to modify its order unless the narrowly defined exceptions apply.”
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