Cf. In re Bonnie E., No. E2021-00919-COA-R3-PT, 2022 WL 1572945, at *5 (Tenn. Ct. App. May 19, 2022) (stating that the testimony "gave the impression that DCS primarily offered Mother visits via video or telephone calls due to the Covid-19 pandemic"). But the trial court in this case found that Mother gave "no reason" for her failure to exercise in-person visitation during the relevant period as she was sober during this time frame while pregnant with her second child.
"Conduct that would amount to a significant restraint or interference with a parent's ability to visit includes 'blocking access to the child,' 'keeping the child's whereabouts unknown,' and 'vigorously resisting a parent's efforts to visit the child.'" In re Bonnie E., No. E2021-00919-COA-R3-PT, 2022 WL 1572945, at *5 (Tenn. Ct. App. May 19, 2022) (quoting In re Audrey S., 182 S.W.3d at 864 n.34).