Louis C. Leithold, Petitioner v. Thyra Nichols Plass and Gilbert Norman Plass, Respondents

Summary

The Texas Supreme Court affirmed the trial court's order modifying only visitation rights, finding that the decree did not alter custody and that a change of conditions justified the visitation modification. The Court reversed the Court of Civil Appeals, which had treated the order as a custody modification. Justice Norvell's dissent argued that the visitation‑custody distinction is immaterial and the child's best interests should govern.