Dolly Parton was not eligible for a Song of the Year Grammy when Whitney Houston’s version of “I Will Always Love You” became a huge hit in 1993, despite Parton having written the song. Houston won Record of the Year and Best Female Pop Vocal Performance in 1994, but Grammy rules had recently been tightened to prevent already prominent songs from competing for the songwriting prize.

The change followed Irving Gordon’s 1992 Song of the Year win for “Unforgettable”, revived by Natalie Cole decades after earlier recordings. Parton had originally taken “I Will Always Love You” to No. 1 on the country chart in 1974, meaning it was considered too well-known before The Bodyguard soundtrack. The current rule allows songs first released or first made prominent during the eligibility period, reflecting the Academy’s continuing attempts to balance new work with revived older songs.