Texas Supreme Court

Tonia Jones, Petitioner v. Lisa Fowler, Respondent

May 8, 199841 Tex. Sup. Ct. J. 808

Summary

The Texas Supreme Court held that the Legislature’s deletion of the word “immediately” from the Family Code standing provision was a nonsubstantive recodification, so the standing requirement remains that a person must have had actual care, custody, and possession of the child for not less than six months preceding the filing. Accordingly, Fowler did not satisfy the standing requirement and the Court reversed the Court of Appeals, granting judgment for Jones.