A Tennessee court has ruled in favor of a father in a custody dispute, affirming a lower court's decision that named him the primary residential parent of his child. The ruling comes after the father, Alex Williams, challenged the existing parenting plan, which had originally designated the mother, Donna Horton (now Howell), as the primary residential parent. The case, Alex Williams v. Donna Horton (Howell), was filed under docket number M2025-00339-COA-R3-CV and decided by the Court of Appeals of Tennessee on September 30, 2026.
This ruling affects both parents and their minor child, as it alters the existing parenting plan and impacts child support obligations. The court found that a material change in circumstances warranted the modification of the parenting plan, which had been in place since 2019. The decision underscores the importance of stability and the best interests of the child in custody cases.
The parties involved in this case are Alex Williams and Donna Horton (Howell), who share a minor child. The dispute arose when Horton expressed her intent to relocate to Washington with the child, citing her husband's military assignment. Williams opposed the move and filed a petition to modify the parenting plan, seeking to become the primary residential parent and gain more parenting time. Horton countered with her own petition to modify the parenting schedule, claiming inconsistencies in the existing plan.
The original parenting plan was agreed upon by both parents in April 2019. Under this plan, Horton was named the primary residential parent, while both parents shared joint decision-making responsibilities. However, the specifics of the plan indicated that Horton had more residential time with the child than Williams. The trial court had to consider whether a material change in circumstances had occurred since the original plan was established.
During the trial, both parents testified, along with Williams' wife. The court found concerns regarding Horton's credibility, particularly due to her prior convictions for aggravated perjury related to her testimony in the initial custody case. Despite her claims of having learned from her past mistakes, the court expressed skepticism about her truthfulness. The court noted, "the Court does not believe Mother when she says that it was her belief that she could choose and Father would be okay with it or that she didn’t have time to look into other schools that may have been available."
Judge Jeffrey Usman presided over the case, with Chief Judge Frank G. Clement, Jr., and Judge Thomas R. Frierson II joining the opinion. The court ultimately decided to affirm the trial court's ruling, stating, "the following constitute material change of circumstances: each of these individuals since the adoption of the Parenting Plan has married, and there are additional adults, stepparents in the home."
The trial court's decision to modify the parenting plan was based on several factors, including the parents' ability to provide a stable environment for the child. The court found that Williams had demonstrated a willingness to facilitate a close relationship between the child and both parents, while Horton had made unilateral decisions regarding the child's education and care without consulting Williams.
The court's ruling has significant implications for both parents and their child. It establishes a new parenting plan that designates Williams as the primary residential parent, which may lead to changes in child support obligations. Additionally, the decision emphasizes the importance of parental cooperation and communication in custody arrangements.
Moving forward, this ruling may set a precedent for future custody cases in Tennessee, particularly regarding the evaluation of material changes in circumstances and the credibility of parents in custody disputes. The court's emphasis on the best interests of the child and the need for a stable environment may influence how similar cases are handled in the future.
As for what’s next, it remains to be seen whether Horton will appeal the decision. The court filing did not indicate any related cases pending at this time. The outcome of this case may also lead to further discussions about parenting plans and custody arrangements in Tennessee.