In the Interest of I.W.O., a Child v. the State of Texas

Texas Court of Appeals, 10th District (Waco)·Decided May 14, 2026·No. 10-24-00031-CV·Published

Opinion

Court of Appeals

Tenth Appellate District of Texas

10-24-00031-CV

In the Interest of I.W.O., a Child

On appeal from the

474th District Court of McLennan County, Texas Judge E. Alan Bennett, presiding Trial Court Cause No. 2017-3767-6

CHIEF JUSTICE JOHNSON delivered the opinion of the Court.

MEMORANDUM OPINION

A jury determined that Father should be appointed sole managing conservator of I.W.O. with the exclusive right to designate his primary residence. The trial court incorporated the jury’s verdict into a final judgment, and Mother appeals from that judgment. In two issues, Mother argues that (1) the trial court abused its discretion by refusing to permit I.W.O. to testify, and (2) the evidence is insufficient to support the jury’s verdict that it is in the best interest of I.W.O. to reside with Father. We affirm.

Background

Mother and Father married on November 20, 2004, and I.W.O. was born on December 29, 2008. The trial court signed a Final Decree of Divorce on October 4, 2018 that named Mother and Father as joint managing conservators of I.W.O. Mother was awarded the exclusive right to designate the primary residence of I.W.O. within 125 miles of the McLennan County Courthouse. Mother also had the exclusive right to (1) consent to medical, dental, and surgical treatment involving invasive procedures, (2) consent to psychiatric and psychological treatment, and (3) make decisions concerning I.W.O.’s education.

I.W.O. was diagnosed with autism when he was approximately two and a half years old. He has normal verbal skills and is able to communicate well with others. I.W.O. has issues with feeding and hygiene, and Mother and Father have opposing views on how to manage those issues. Mother homeschools I.W.O., and he attends a co-op for homeschool children one day a week. Mother and Father also disagree on I.W.O.’s educational environment. Another issue arose when Mother and Father disagreed over a major surgery to correct I.W.O.’s tibial torsion. Father was unsure that the surgery was medically necessary, while Mother wanted I.W.O. to have the surgery.

Sometime in early 2022, I.W.O. refused to have visitation with Father, which continued until the time of trial. On March 25, 2022, Father filed a petition to modify the parent-child relationship. Mother then filed a counterpetition in which she asked to be appointed as sole managing conservator of I.W.O. Father amended his petition to modify the parent-child relationship and requested that he be named the sole managing conservator of I.W.O.

A jury determined that Father should be appointed as I.W.O.’s sole managing conservator with the exclusive right to designate his primary residence. The trial court signed a judgment in accordance with the jury’s verdict, and Mother appeals.

Issue One

In the first issue, Mother argues that the trial court abused its discretion by refusing to permit I.W.O. to testify at trial. Standard of Review We review the trial court’s decision to admit evidence for an abuse of discretion. In re J.P.B., 180 S.W.3d 570, 575 (Tex. 2005); In re R.R., 711 S.W.3d 126, 136 (Tex. App.—Houston [1st Dist.] 2024, no pet.). A trial court abuses its discretion when it acts without regard for any guiding rules or principles. Low v. Henry, 221 S.W.3d 609, 614 (Tex. 2007). We may not reverse the trial

court’s order unless we conclude that the evidentiary error probably caused the rendition of an improper judgment or probably prevented the appellant from properly presenting the case to the court of appeals. See TEX. R. APP. P. 44.1(a); In re R.R., 711 S.W.3d at 136. Applicable Law Rule of Evidence 403 allows for the exclusion of relevant evidence if the probative value of the evidence is substantially outweighed by a danger of one or more of the following: unfair prejudice, confusing the issues, misleading the jury, undue delay, wasting time, or needlessly presenting cumulative evidence. TEX. R. EVID. 403. Discussion After two days of testimony at trial, Mother stated that she intended to call I.W.O. to testify. Father objected under Rule 403 arguing that the testimony was unnecessarily cumulative. Mother maintained that the testimony was relevant because it went to the central issues in the case, which Mother’s counsel characterized as I.W.O.’s desire as to who he wants to make decisions concerning his medical treatment and education. The trial court agreed that I.W.O.’s testimony should be excluded under Rule 403.

On the final day of testimony, Mother reurged her request to call I.W.O.

to testify. Mother’s counsel prepared a brief in support of her argument that

I.W.O. should be allowed to testify and read that brief on the record. Mother argued that Father failed to offer any basis for excluding the evidence under Rule 403 and that there was no explanation as to why I.W.O.’s testimony giving his personal opinion about who he wants to live with would confuse the jury. The trial court maintained its original ruling and excluded I.W.O.’s testimony.

Mother was allowed to call I.W.O. to make an offer of proof. I.W.O. stated that he is homeschooled by Mother and that he goes to the co-op one day a week. He said that he socializes with other children at the co-op and at church. I.W.O. testified that he is comfortable with his educational setting and that he wants to stay in that same setting. I.W.O. described that he has tibial torsion that causes pain when he walks or runs. He expressed his desire to have surgery to correct the tibial torsion.

I.W.O. further testified at the offer of proof that he made the decision to stop having visitation with Father in February 2022. He explained that Father would not help him with his hygiene issues and did not properly prepare his food. I.W.O. did not believe that Father would ever change and stated that he would not like to live with him.

Mother argues that when a child who is competent to testify is called as a witness, the trial court does not have discretion to refuse to permit the child to testify, citing Callicott v. Callicott as authority. 364 S.W.2d 455 (Tex. Civ.

App.—Houston 1963, writ ref’d n.r.e.). In Callicott, the Appellant father had custody of the eight-year-old child, and the Appellee mother sought to change the custody arrangement. Id. at 456. Appellant called the child as a witness and requested that the child be examined in open court or in chambers. Id. at 457. The trial court sustained Appellee’s objection that the child was incompetent to testify. Id. The trial court did not interview the child in chambers to determine his competency and did not allow Appellant to make a bill of exceptions. Id. at 456.

On appeal, the court held that the trial court erred in refusing to grant Appellant’s request to examine the child either in open court or in chambers. Id. at 457. The court noted that in chambers the trial court could have readily determined the qualifications of the child to testify. Id. The court stated that “[w]here a child of competent qualifications under the rules of evidence is called to testify, the trial court does not have within his discretion the right to refuse to permit such child to testify.” Id. at 458.

In Callicott, the court of appeals noted that the trial court did not talk to the child and did not allow Appellant to properly prepare a bill of exceptions to show the child’s qualifications to testify and what he would have testified to. Id. at 458. Unlike Callicott, in the case before us, the trial court did not exclude I.W.O.’s testimony based upon his competency. While the court in Callicott

stated that a trial court does not have the discretion to permit a child of competent qualifications to testify, the court did not hold that the Texas Rules of Evidence do not apply to a child’s testimony. Therefore, we cannot conclude that Callicott stands for the proposition that a child’s testimony is not subject to the rules of evidence.

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In the Interest of I.W.O., a Child v. the State of Texas, (Tex. Ct. App. 2026).

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