In Martin v. Martin, 776 S.W.2d 572, 574 (Tex. 1989), the Court decided that under this earlier version of section 105.002, a trial court's decree could contravene the jury's verdict on the specific terms and conditions of access to the child, including primary residence. Confusion arose, however, over the relationship between binding jury verdicts on custody, see TEX. FAM. CODE 105.002, and court-determined conservatorship terms. See JOHN J. SAMPSON ET AL., SAMPSON & TINDALL'S TEXAS FAMILY CODE ANNOTATED 105.002 cmt. (11th ed. 2001). That is, when a jury awarded joint managing conservatorship as the custody arrangement, it was unclear whether the child's primary residence should be considered a term of the conservatorship, an issue determined by the trial court. See id. If so, the trial court had the authority to designate the child's primary residence. See id. The possibility that such authority would ultimately thwart the jury's will in determining custody raised concern. See id.; HOUSE COMM. ON JUVENILE JUSTICE & FAMILY ISSUES, BILL ANALYSIS, Tex. H.B. 646, 75th Leg., R.S. (1997).