Family lawyers in Texas watched the progress of the case In Re C.J.C. through the Texas court system for some time to see if it would make new case law in situations in which a nonparent, in a suit for modification, requests visitation rights with a child whose parent was previously awarded conservatorship and possession of the child. A Texas Supreme Court ruling in this case, just announced in June, answers some questions but may have raised other even more difficult issues that are not yet settled in Texas law.

The story in this particular case is a sad one. A six-year old named “Abigail” in TSC documents has already seen a lot of changes in her young life. Abigail’s parents lived together from 2011 to 2016 but never married. Abigail was born in 2014.

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