In re V.L.K

In In re V.L.K., 24 S.W.3d 338, 343 (Tex. 2000), the Court noted that Family Code chapter 153, governing original child-custody determinations, and Family Code chapter 156, governing modification proceedings, "are distinct statutory schemes that involve different issues." Id. But V.L.K. did not concern judicial disqualification or rule 18b(1)(a). Instead, in V.L.K., we held the presumption that a child's best interest is served by awarding custody to the parent in original custody proceedings does not apply in modification proceedings brought under chapter 156. Id. at 339-40. The Court recognized that the Legislature imposed different standards and burdens of proof in original custody and modification proceedings. Id. at 343. The Court also noted that modification proceedings raise additional policy concerns such as stability for the child and the need to prevent constant litigation in child custody cases. Id.