The termination of parental rights action In re. Z.C.G. No. M2000-02939-COA-R3-CV was a close call, that was properly made by the Tennessee Middle Section Appellate Court.  It appears the mother as custodial parent did not promote the parent-child relationship with the father, and went a step further to minor visitation interference.  The significance of this cannot be understated.  If there is not active promotion by the custodial parent, with standard visitation in a few years the child and the other parent become estranged.  In light of that reality the father here in not fulfilling his parental responsibilities (visitation) can to some extent be understood.   

   The father did clearly exacerbate the situation by threatening the mother (apparently hollow).  That's hard for a judge to not act upon, but as long as it is bluster, and doesn't subject the child to danger, it's an unnecessary quagmire for the state to get involved in.  It's undesirable and impossible to micromanage the lives of adults if they are acting mildly irresponsible, as both parents in this case did, as long as it does not rise to a serious level.  This is the hallmark of a free society.

   In re. Z.C.G. has the inherent concept of rights and responsibilities being linked together.  The father did not vigorously pursue his responsibilities, and thus as Justices Cain, Cantrell, and Cottrell, wisely noted, "However, the foregoing being said, Mr. Goins is certainly skating on thin ice with regard to his parental rights."

  Although not cited, the constitutional rule is the state cannot interfere with the parent-child relationship lacking a finding of severe (substantial) harm.  If a parent abandons his or her child this does place the child in severe harm (even if fully provided for in all other ways, the risk of severe psychological harm trips the threshold).  So while parental abandonment does allow for state intervention, current state practice of terminating parental rights needs to be considered.

   It would seem a better course of action is to place sanctions on the abandoning parent, such as is done today with failure to provide the financial half of child support.  This would properly put emotional and financial support on an equal footing.  This policy would send a clear signal to citizens that when they bear a child, they will fully care for it, not the state or other third parties.  That will be beneficial for children and society.