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Reading: Dolly Parton Wasn’t Eligible for Song of the Year Grammy for ‘I Will Always Love You’ for This ‘Unforgettable’ Reason
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Music World > News > Dolly Parton Wasn’t Eligible for Song of the Year Grammy for ‘I Will Always Love You’ for This ‘Unforgettable’ Reason
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Dolly Parton Wasn’t Eligible for Song of the Year Grammy for ‘I Will Always Love You’ for This ‘Unforgettable’ Reason

Written by: News Room Last updated: August 28, 2026
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Whitney Houston won two Grammys for her blockbuster hit “I Will Always Love You” at the 36th Grammy Awards on March 1, 1994. She took record of the year and best pop vocal performance, female.

As the producer of the smash, David Foster shared the award for record of the year and also won producer of the year, non-classical, largely because of his work on the hit. But Dolly Parton wasn’t recognized for writing the song. She would have been a shoo-in to win song of the year but wasn’t eligible. She had first recorded the song in 1974, taking it to No. 1 on Hot Country Songs.

So, songs that were already well-known weren’t eligible? That rule has changed over the years.

Just two years earlier, Irving Gordon won song of the year for “Unforgettable,” which had been a pop standard for 40 years at that point, since Nat King Cole and Doris Day had recorded it in the early 1950s. Dinah Washington had a top 20 hit on the Hot 100 with the song in 1959. It won in 1992 because Natalie Cole’s sentimental recording of the song as a duet with her late father brought it back to prominence.

“Unforgettable” was a great song, no doubt, but should it have taken the top songwriting award in 1992 against such great contemporary songs as R.E.M.’s “Losing My Religion” or Marc Cohn’s “Walking in Memphis” (both of which were also nominated in that category)?

The Recording Academy decided the eligibility rule needed to be tightened, so that already famous songs wouldn’t be eligible. That was bad news for Parton’s song, even though it was no more famous pre-The Bodyguard than “Unforgettable” was prior to Natalie Cole’s revival of the song.

The Grammys have tinkered with the rules on song of the year (and also best new artist, for different reasons) many times, trying to strike just the right balance. The current rule states: “A song… must have been released on a recording for the first time, or achieved prominence for the first time, during the current eligibility period.”

Most of the song of the year winners in Grammy history were new songs that year, or songs that weren’t previously widely known. Jimmy Driftwood’s “The Battle of New Orleans,” which won in 1960, was written way back in 1936, but had not been a hit until Johnny Horton covered it in 1959.

Here are eight song of the year winners preceding “Unforgettable” that were already known to widely varying degrees. The years shown are the years of the Grammy presentations.

  • “The First Time Ever I Saw Your Face” (1973)

    This Ewan MacColl song won on the strength of Roberta Flack’s smash 1972 recording, which was the first version of the song to make the Billboard Hot 100. But by then it had been recorded on hit albums by numerous acts, including The Kingston Trio, The Chad Mitchell Trio, Peter, Paul & Mary and Harry Belafonte.

  • “Send in the Clowns” (1976)

    The popularity of Judy Collins’ version, which made the top 40 on the Hot 100 in 1975, lifted this Stephen Sondheim song to victory. But it had first appeared in 1973 on the Broadway cast album to A Little Night Music, which won a Grammy for best musical theater album, and a few months later, on Frank Sinatra’s Ol’ Blue Eyes Is Back, a top 20 album on the Billboard 200. Cleo Laine and Shirley Bassey also recorded it before Collins.

  • “I Write the Songs” (1977)

    This Bruce Johnston ballad won on the strength of Barry Manilow’s smash cover version, but the Captain & Tennille were first to record it, on their Love Will Keep Us Together album (which was released four months before Manilow’s album Tryin’ to Get the Feeling (and in the previous Grammy eligibility year). C&T had some history with Johnston. They worked with him in the early 1970s with The Beach Boys.

  • “Bette Davis Eyes” (1982)

    Kim Carnes’ synth-rock version of this song, which topped the Hot 100 for nine weeks in 1981, carried the Donna Weiss/Jackie DeShannon song to victory. And the song was new to most listeners. Only DeShannon die-hards knew that it had first appeared on the veteran singer/songwriter’s 1975 album New Arrangement.

  • “Always on My Mind” (1983)

    This poignant ballad won on the strength of Willie Nelson’s classic 1982 recording. But the Johnny Christopher/Mark James/Wayne Carson song was a decade old by that point. It was first recorded by Brenda Lee and was first released by R&B singer Gwen McCrae (as “You Were Always on My Mind”) in March 1972. Lee’s version was released three months later. Elvis Presley’s 1972 recording, the B side of his top 20 Hot 100 hit “Separate Ways,” was the first commercially successful version of the song.

  • “That’s What Friends Are For” (1986)

    Dionne & Friends’ version of this Burt Bacharach/Carole Bayer Sager song, which raised money and consciousness about the AIDS crisis, was the first to make the Hot 100, but Rod Stewart had performed the song on the soundtrack to the Ron Howard-directed comedy Night Shift in 1982.

  • “Wind Beneath My Wings” (1990)

    This song won on the strength of Bette Midler’s Hot 100-topping version, which was featured in the film Beaches, which starred Midler and Barbara Hershey as the friend “who always walked a step behind.” But it wasn’t the first version of the Larry Henley/ Jeff Silbar song to make the Hot 100. R&B singer Lou Rawls took it to No. 65 in 1983. Glady Knight & the Pips bubbled under the Hot 100 (at No. 104) that same year with a version titled “Hero.” Sheena Easton, Lee Greenwood, Gary Morris, B.J. Thomas and Willie Nelson also included the song on hit albums before Midler made it a smash.

  • “From a Distance” (1991)

    This Julie Gold song is best-known for the Bette Midler version, which reached No. 2 on the Hot 100. But it was written in 1985 and first recorded by Nanci Griffith, for her 1987 album Lone Star State of Mind. The album didn’t make the Billboard 200, but it reached No. 23 on Top Country Albums. So, the song was hiding in plain sight.

TAGGED: Awards, Featured, Grammy award, songwriting
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