Taylor v. Meek

In Taylor v. Meek, 154 Tex. 305, 276 S.W.2d 787, 790 (Tex. 1955), the maternal grandparents were named managing conservators in the parent's divorce decree. See Taylor, 276 S.W.2d at 788. Several years later, the father sought to modify the order to regain custody of his daughter. See Taylor, 276 S.W.2d at 788. This Court noted that, after a court has awarded custody to a nonparent, a parent cannot merely show that she is a fit person to be entitled to custody. See Taylor, 276 S.W.2d at 789. Instead, the court should order a change only when convinced that the change is a positive improvement for the child. See Taylor, 276 S.W.2d at 790. The Court noted that there is a difference between an original conservatorship determination and a modification: "Because a change of custody disrupts the child's living arrangements and the channels of a child's affection, a change should be ordered only when the trial court is convinced that the change is to be a positive improvement for the child." Taylor, 276 S.W.2d at 790.