Phillips v. Beaber

A court that renders a final order in a suit affecting the parent-child relationship generally retains continuing, exclusive jurisdiction to modify the order. Tex. Fam. Code §§ 155.001(a), 155.003(a). This jurisdiction may be exercised to modify visitation, which is defined as “possession of and access to a child,” Tex. Fam.Code § 152.002(11), but not to modify “custody” if the child and the custodial parent have established another home state, as in the present case. Tex. Fam.Code § 152.003(c) & (d). We must decide whether a parent’s motion to modify, which seeks to obtain primary possession…