Edith Atha Taylor v. Lenton Meek

Summary

The Texas Supreme Court affirmed the trial court’s award of custody to the maternal grandparents, holding that the trial court did not abuse its discretion. The Court reversed the Court of Civil Appeals, stating that a natural parent’s proof of changed conditions and fitness does not automatically entitle him to custody absent a finding of abuse of discretion. The decision reiterates that the presumption favoring natural parents is rebuttable and does not control a suit to modify a prior custody decree.