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13 Texas opinions name it 1 courts 2016–2024 5 in the last five years
The cases below were cited by Texas courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Smith v. Karanjagreen2 sentences2024“The change-in-circumstances requirement is a threshold issue for the trial court and is based on a policy of preventing constant re-litigation with respect to children.” Smith v. Karanja, 546 S.W.3d 734, 738 (Tex. App.—Houston [1st Dist.] 2018, no pet.); see also In re A.L.E., 279 2 Sherard became engaged to her current husband in January 2020, before the divorce decree was signed on January 30, 2020. 2023“The change-in-circumstances requirement is a threshold issue for the trial court and is based on a policy of preventing constant re-litigation with respect to children.” Smith v. Karanja, 546 S.W.3d 734, 738 (Tex. App.—Houston [1st Dist.] 2018, no pet.). | 9 | 9 |
In Re ALEgreen2 sentences2020“The change-in-circumstances requirement is a threshold issue for the trial court and is based on a policy of preventing constant re-litigation with respect to children.” Smith v. Karanja, 546 S.W.3d 734, 738 (Tex. App.—Houston [1st Dist.] 2018, no pet.); In re A.L.E., 279 S.W.3d 424, 428 (Tex. App.—Houston [14th Dist.] 2009, no pet.) (“In an effort to ensure stability and continuity for children, Texas law has imposed ‘significant hurdles’ before a conservatorship order may be modified.”). 2019“The change-in-circumstances requirement is a threshold issue for the trial court and is based on a policy of preventing constant re-litigation with respect to children.” Smith v. Karanja, 546 S.W.3d 734, 738 (Tex. App.— Houston [1st Dist.] 2018, no pet.); see In re A.L.E., 279 S.W.3d 424, 428 (Tex. App.—Houston [14th Dist.] 2009, no pet.) (“In an effort to ensure stability and continuity for children, Texas law has imposed ‘significant hurdles’ before a conservatorship order may be modified.”). | 6 | 6 |
Zeifman v. Michelsgreen2 sentences2019Smith v. Karanja, 546 S.W.3d 734, 738 (Tex. App.—Houston [1st Dist.] 2018, no pet.); see also In re A.L.E., 279 S.W.3d 424, 428 (Tex. App.—Houston [14th Dist.] 2009, no pet.); Zeifman, 212 S.W.3d at 595 (“The requirement of this showing serves a valid purpose of significantly limiting the trial [court’s] discretion and prevents the modification statute from being unconstitutionally broad.” (internal quotations omitted)). 2018See In re A.L.E. , 279 S.W.3d 424 , 428 (Tex. App.-Houston [14th Dist.] 2009, no pet.) ("As a threshold determination, then, the moving party must show a material and substantial change in circumstances; otherwise, the petition must be denied."); Zeifman v. Michels , 212 S.W.3d 582 , 595 (Tex. App.-Austin 2006, pet. denied) ("The requirement of this showing 'serves a valid purpose of significantly limiting the trial judge's discretion and prevents the modification statute from being unconstitutionally broad.' "). | 1 | 4 |
In the Interest of T.M.P. and J.C.P., Childrengreen1 sentence2019Material and substantial change “In a modification suit, the threshold inquiry is whether the moving party has met the burden of demonstrating a material and substantial change.” In re T.M.P., 417 S.W.3d 557, 563 (Tex. App.—El Paso 2013, no pet.); see Smith v. Karanja, 546 S.W.3d 734, 738 (Tex. App.—Houston [1st Dist.] 2018, no pet.) (“The change-in- circumstances requirement is a threshold issue for the trial court and is based on a policy of preventing constant re-litigation with respect to children.”). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Texas. Read the followed side critically anyway. | ||
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.