Dolly Parton Wasn’t Eligible for Song of the Year Grammy for ‘I Will Always Love You’ for This ‘Unforgettable’ Reason

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” is 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 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 country star Johnny Horton covered it in 1959.

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