Texas Supreme Court
P. B. Lakey v. R. O. McCarroll
January 3, 1940134 Tex. 191
Summary
The Texas Supreme Court held that Article 4639a does not give the original divorce court continuing exclusive jurisdiction over later custody actions, so venue for a suit to relitigate custody lies in the defendant's county of residence, Dawson County. The Court answered two certified questions affirming that the statute is cumulative and does not alter pre‑existing venue rules.