in the Interest of J.E., a Child, 02-20-00105-CV

Parents signed a mediated settlement agreement (Jan 2018) and divorced (Apr 2018); they were named joint managing conservators and Father was given exclusive right to designate the child’s primary residence.
Under the original decree Mother had more-than-presumptive possession: first/third/fifth weekends, Thursday overnights during the school term, and alternating weeks in summer.
After the decree Father remarried; his new wife (Stepmother) began student-teaching and later teaching at the child’s school; the child started pre-K in Aug 2018 and was in kindergarten at trial.
Mother moved, became engaged, and filed to modify (Mar 2019); Father counterclaimed seeking reduced possession and the exclusive right over the child’s psychological/psychiatric care (particularly inpatient care).
Bench trial (Dec 2019): trial court awarded Father exclusive educational decision-making, enjoined posting the child’s pictures on social media, converted Mother’s school‑term possession to (essentially) a standard order with Thursdays 5–7 p.m. (eliminating overnight school‑night stays), and gave Father exclusive authority over any inpatient mental‑health care while preserving independent outpatient consent.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court abused its discretion by reducing Mother’s possession below presumptive minimums	Mother: No evidence of the parties’ circumstances at the MSA or a material/substantial change; no evidence change was in child’s best interest	Father: Evidence of material/substantial change (child began school; stepmother teaching at school; child tired/moody after Mother’s overnights) and evidence supporting best interest; trial court did not remove more time than permitted	Court: Affirmed — some evidence supports a material & substantial change and the implied best‑interest finding; no abuse of discretion
Whether awarding Father exclusive authority over inpatient psychiatric/psychological care is supported by evidence	Mother: No evidence supports stripping her of inpatient‑care decision rights	Father: Circumstantial evidence of parental conflict over counseling (Mother unilaterally resumed therapy; differing views); expert testified joint rights can be problematic; exclusive inpatient authority avoids conflicting inpatient placements	Court: Affirmed — circumstantial evidence supports awarding Father exclusive inpatient‑care decision authority; no abuse of discretion

Iliff v. Iliff, 339 S.W.3d 74 (Tex. 2011) (abuse‑of‑discretion standard in family‑law matters)
Lenz v. Lenz, 79 S.W.3d 10 (Tex. 2002) (conservatorship determinations are fact‑driven)
Holley v. Adams, 544 S.W.2d 367 (Tex. 1976) (best‑interest factors for child‑custody decisions)
City of Keller v. Wilson, 168 S.W.3d 802 (Tex. 2005) (standards for legal‑sufficiency review)
Shields Ltd. P’ship v. Bradberry, 526 S.W.3d 471 (Tex. 2017) (standards for no‑evidence challenges)
Unifund CCR Partners v. Villa, 299 S.W.3d 92 (Tex. 2009) (factfinder may rely on some evidence amid conflicting proof)
In re Barber, 982 S.W.2d 364 (Tex. 1998) (factfinder’s role in weighing conflicting evidence)
Trammell v. Trammell, 485 S.W.3d 571 (Tex. App.—Houston [1st Dist.] 2016) (parental decision‑making for mental‑health treatment can be modified)