Turner v. Turner (1995)

Mr & Mrs Turner married in 1984. This couple had 2 children prior to their separation in 1987.

Mrs Turner filed for divorce in 1989 & received custody of the 2 children.

Mr Turner was granted visitation rights. He operated an auto salvage business with irregular income. At the time of the divorce, Mr Turner had a net operating loss (NOL).

In early 1991, the Tennessee trial court found Mr Turner in contempt for failing to pay Child support in the United States. In February 1994, Mr Turner was sentenced to 6 months in jail & suspended his visitation rights.

May a family court deny a non-custodial parent visitation due to the parent's failure to pay child support without 1st determining why this failure has occurred?

Visitation decisions aren't punitive. Visitation shouldn't be denied without a determination that the parent could've paid child support but refused.