## Facts

- Reynaldo Manuel Aragon (Father) and Cassidy Lynne Aragon (Mother) divorced in Tennessee and had one child.
- Their agreed parenting plan did not name a primary residential parent and split parenting time equally (182.5 days each).
- In practice, Mother worked overseas for extended periods, and Father exercised most residential parenting time.
- After completing nursing school, Father obtained an advantageous nursing job offer in Arizona and sought to relocate with the child, citing employment and proximity to extended family support.
- Mother opposed relocation, asserting it would reduce her parenting time and separate the child from a half-sibling in Tennessee.
- The trial court applied Tenn. Code Ann. § 36-6-108, denied relocation for lack of a “reasonable purpose,” and modified the plan to designate Mother as primary residential parent.
- The Court of Appeals affirmed, applying prior precedent that treated “reasonable purpose” as requiring more than ordinary reasons and effectively weighed the move’s benefits against the nonmoving parent’s loss.
- The Tennessee Supreme Court granted review to clarify the “reasonable purpose” standard under the relocation statute.

## Issues

1. What standard governs whether a proposed relocation has a “reasonable purpose” under Tenn. Code Ann. § 36-6-108?
2. Under the correct standard, did Father’s job-related and family-support reasons constitute a reasonable purpose?
3. Did Mother, as the nonrelocating parent, prove a statutory ground to deny relocation when the relocating parent had greater residential time?

## Decision

- The Tennessee Supreme Court reversed the Court of Appeals and trial court.
- The Court overruled prior precedent to the extent it imposed a heightened, comparative “reasonable purpose” test.
- The Court held Father’s advantageous job opportunity and family-support considerations were a reasonable purpose for relocation.
- The Court held Mother did not prove any statutory ground to deny relocation (including lack of reasonable purpose).
- The Court remanded for entry of orders consistent with the opinion, including a transitional parenting plan and designation of Father as primary residential parent.

## Legal Principles

- Statutory terms in the parental relocation statute are construed using their natural and ordinary meaning absent contrary legislative intent.
- Under Tenn. Code Ann. § 36-6-108, when the relocating parent spends the greater amount of time with the child, relocation is presumed permissible unless the nonrelocating parent proves a statutory ground for denial (e.g., no reasonable purpose, vindictiveness, or specific and serious harm to the child).
- “Reasonable purpose” means an objectively sensible, non-irrational reason in light of the circumstances; it does not require an extraordinary, substantial, or comparative showing that the new location is “better” than the existing one.
- Courts may not shift the statutory burden by requiring the relocating parent to prove superiority of the destination or to negate the nonrelocating parent’s anticipated loss of parenting time.

## Conclusion

The Tennessee Supreme Court clarified that “reasonable purpose” under the parental relocation statute is an ordinary, objective standard and that, where the primary residential caregiver has a sensible reason such as improved employment and family support, relocation must be allowed unless the nonmoving parent proves a statutory ground to deny it.


Aragon v. Aragon, 513 S.W.3d 447 (Tenn. 2017)