Whitney Houston won record of the year and best pop vocal performance, female, for ‘I Will Always Love You’ at the 36th Grammy Awards on March 1, 1994. Producer David Foster shared the record of the year award and won producer of the year, non-classical, largely for his work on the hit. However, Dolly Parton, who wrote and first recorded the song in 1974—taking it to No. 1 on Hot Country Songs—was ineligible for song of the year.
The Recording Academy had tightened song of the year eligibility rules after the 1992 Grammy Awards, when Irving Gordon won the award for ‘Unforgettable,’ a pop standard that had been around for about 40 years, with early versions recorded in the 1950s. That song returned to prominence through Natalie Cole’s recording of it as a duet with her late father. The rule change was intended to prevent already-famous songs from competing, which put Parton’s song, despite not being widely famous before ‘The Bodyguard,’ at a similar disadvantage. The current eligibility rule requires a song to have been ‘released on a recording for the first time, or achieved prominence for the first time, during the current eligibility period.’
Most song of the year winners in Grammy history were new songs that year or previously unknown compositions. Examples include Jimmy Driftwood’s ‘The Battle of New Orleans,’ written in 1936 but not a hit until Johnny Horton covered it in 1959, which won in 1960.
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Source: Billboard
