In the Interest of M.G., a child — Memorandum Opinion by Justice Wise
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Affirmed and Memorandum Opinion filed October 22, 2026 In The Fourteenth Court of Appeals NO. 14-25-01164-CV IN THE INTEREST OF M.G., A CHILD On Appeal from the 247th District Court Harris County, Texas Trial Court Cause No. 2024-82735 MEMORANDUM OPINION In this suit affecting the parent–child relationship, Father appeals pro se from a final order following a bench trial that named him and Mother joint managing conservators of their two-year-old daughter, allocated parental rights among them, set terms for possession and access, and ordered him to pay child support. Father challenges the judgment in fifty issues, which he separates into four categories: procedural and due process, child support, conservatorship and possession, and the trial court’s findings.1 1 A list of Father’s issues is appended to this opinion.
2 We address his issues to the extent possible although his brief does not contain adequate citations to authorities to support his arguments.2 We hold as follows: • Father did not preserve error regarding his complaints about the trial procedure (Issues 1–9). • Father has not shown error regarding the trial court’s child support order, findings, or procedure (Issues 11–24 and 44–48). • Father’s challenges to the “under three” possession order are moot (Issues 34–36, 38–39, and 43). • Father has not shown error regarding the trial court’s conservatorship order and findings (Issues 26–29, 31–33, 37, and 49). • Assuming error in the trial court’s conclusion that the court did not limit Father’s parental rights, it was harmless (Issues 30 and 41–42). • Father has not shown cumulative error (Issues 10, 25, 40, and 50). The trial court’s judgment is affirmed. I. PROCEDURAL C OMPLAINTS In Issues 1–9, Father complains about procedural concerns such as the trial court’s time limitation for the trial, reopening of the evidence under Rule 270 of the Rules of Civil Procedure, and limitation of the subject matter of the reopening. He contends that he was denied due process. 2 See Borusan Mannesmann Pipe US, Inc. v. Hunting Energy Servs., LLC, 716 S.W.3d 572, 575–76 (Tex. 2025) (no briefing waiver despite appellant’s failure to cite any appropriate authority, but this court may resolve appeal without requesting additional briefing).
3 A. Background Father agreed that the bench trial would take “no more than” three hours, and he did not object to the trial court’s time limit suggestion.3 He did not ask for more time. He rested his case after questioning Mother. During the trial, Mother did not present any evidence about Father’s income. But Father testified that he was a veteran “going through my disability claim right now.” He testified about his intent to “put [the Child] on my VA benefits, to allow her to be able to have those benefits that she’s entitled to receive.” After the trial but before the court signed a final judgment, Mother filed a motion to reopen the evidence because Father disclosed that he was receiving disability income, which would affect the calculation of net resources for purposes of awarding child support. Father did not file a response. At a hearing on the motion, Father objected “to the child support,” arguing, “The reason why I object to the child support is because I provide for [the Child] when she is under my care.” Later, when Father again argued that he was asking for the court to “set the child support at zero” because he provided for the child while 3 After the court took announcements, the following occurred: COURT: Thank you very much. Okay. We are here for final trial today and I think that the estimate was about three hours, or no more than. FATHER: Yeah, no more than. COURT: Okay. So we’re here this morning and I hope that we can finish before noon today. I’m going to equalize your time as much as I can, so each party will have an hour and a half of testimony and argument; and if, in fact, we need—if one of you needs less time and the other needs more, we’ll try to figure it out. I don’t want to cut anybody off at the knees, but I do want to try to be as efficient as we can with our time. Are there any housekeeping issues to address before we start? Any preliminary issues to talk about before we begin our testimony? FATHER: None on my behalf.
4 she was in his care, the court explained, “That’s outside the scope of a Motion to Reopen Evidence because the Motion to Reopen is not re-arguing what’s already been presented.” Father did not otherwise object to the reopening of the evidence or any limitations placed on him. B. Preservation Principles “Generally, to preserve a complaint for appellate review: (1) a party must complain to the trial court by a timely and specific request, objection, or motion that complies with applicable evidentiary, procedural, and appellate rules; and (2) the trial court must rule or refuse to rule on the request, objection, or motion.” Samson Expl., LLC v. T.S. Reed Props., Inc., 521 S.W.3d 766, 782 (Tex. 2017) (citing Tex. R. App. P. 33.1). A party’s argument on appeal must correspond with the argument made in the trial court. Intertek USA, Inc. v. Trical Com. Invs., LLC, No. 14-23- 00475-CV, 2025 WL 2496264, at *12 (Tex. App.—Houston [14th Dist.] Aug. 29, 2025, pet. denied) (mem. op.) (“An objection in the trial court based on one legal theory may not be used to support a different legal theory on appeal.”). Generally, courts require error preservation for complaints about time limitations during trial,4 4 See Kinney v. Batten, No. 01-21-00394-CV, 2023 WL 2316354, at *8 (Tex. App.— Houston [1st Dist.] Mar. 2, 2023, pet. denied) (mem. op.); McCaffety v. Blanchard, No. 01-15- 01077-CV, 2018 WL 542390, at *2 (Tex. App.—Houston [1st Dist.] Jan. 25, 2018, pet. denied) (mem. op.).
5 other limitations on the examination of witnesses,5 reopening for additional evidence,6 and violations of due process.7 C. No Preservation Because Father did not complain to the trial court about any time or content limitations, the reopening of evidence, or procedural issue affecting due process, he has not preserved these alleged errors. See Tex. R. App. P. 33.1; supra notes 4–7 and accompanying text. To the extent any of these issues include arguments related to the merits of the child support determination, we address Father’s arguments about child support below. Issues 1–9 are overruled. II. C HILD SUPPORT In Issues 11–24 and 44–48, Father contends that the trial court erred by awarding child support under the guidelines, which the court calculated based on his Department of Veterans Affairs (VA) disability benefits. Father primarily complains about the inclusion of his entire VA disability benefits in the net resources calculation, the court’s failure to determine the “dependent component” of his benefits so he could receive a credit or offset, and the court’s denial of a deviation from the guidelines. We address these contentions and others in greater detail below. 5 See Jackson v. Jackson, No. 14-07-00917-CV, 2009 WL 1124354, at *2 (Tex. App.— Houston [14th Dist.] Apr. 28, 2009, no pet.) (mem. op.). 6 City of Houston v. Wisnoski, 460 S.W.2d 488, 490 (Tex. App.—Houston [14th Dist.] 1970, writ ref’d n.r.e.). 7 See In re L.M.I., 119 S.W.3d 707, 710–11 (Tex. 2003); Jafri v. Aljuhani, No. 14-24- 00692-CV, 2026 WL 775419, at *7 (Tex. App.—Houston [14th Dist.] Mar. 19, 2026, no pet.) (mem. op.)
6 A. Standard of Review and Legal Principles A trial court has discretion to set child support within the parameters of the Family Code. Iliff v. Iliff, 139 S.W.3d 74, 78 (Tex. 2011). We may not disturb the trial court’s order unless the complaining party shows a clear abuse of discretion. Id. A trial court abuses its discretion by acting arbitrarily or unreasonably, without reference to guiding rules or principles, or by failing to analyze or apply the law correctly. Id. A trial court abuses its discretion when there is no evidence to support the award of child support. See In re Marriage of Butts, 444 S.W.3d 147, 154 (Tex. App.—Houston [14th Dist.] 2014, no pet.). A trial court as a fact finder is the sole judge of the witnesses’ credibility and the weight to be given to their testimony. Iliff, 339 S.W.3d at 83. The purpose of child support is to help a custodial parent maintain an adequate standard of living for the child. Williams v. Patton, 821 S.W.2d 141, 145 (Tex. 1991). In setting an amount of child support, the paramount guiding principle is always the best interest of the child. Iliff, 339 S.W.3d at 81. A court must presumptively apply guidelines established by the Family Code for setting child support. See Tex. Fam. Code § 154.125(b). Generally, for one child as in this case, the guidelines provide that child support should be an amount equal to twenty percent of an obligor’s monthly net resources. See id. Net resources include “United States Department of Veterans Affairs disability benefits other than non-service-connected disability pension benefits.” Id. § 154.062(b)(5). But, if the child receives periodic benefits as a result of the obligor’s disability, then the court must subtract the amount of the benefits “paid to or for the child as a result of the obligor’s disability” from the presumptive guidelines amount when ordering child support. Id. § 154.132(a).
7 An order conforming to the guidelines is presumed to be in the child’s best interest. Id. § 154.122(a). But a court may determine that the guidelines amount would be unjust or inappropriate under the circumstances. Id. § 154.122(b); see id. § 154.123(b). A court may order child support in an amount outside the guidelines if the evidence rebuts the presumption that the guidelines amount is in the child’s best interest and the evidence justifies a variance from the guidelines. Id. § 154.123(a); see also id. § 154.123(b) (identifying some relevant factors for the court to consider). B. Evidence and Proceedings Father testified that he began receiving a service-connected disability benefit from the VA in late August in the amount of $3,974 per month, which was “in addition to the dependent allowance.” During the hearing, he explained, “I’m trying to find the chart so I can tell you specifically how much I receive for [the Child] every month.” He believed that for one child, he received “$109 additionally.” He received the “dependent portion directly.” When asked if he sends the additional amount to Mother, he testified, “I just sent [Mother] $430.” But he also clarified that the $430 was not for child support. He sent her the money “just out of a token of appreciation,” and it was “just me being a blessing to her since I received a blessing.” During the hearing, the court reviewed Section 154.062(b)(5) and suggested that Father’s VA benefits would be included in net resources for purposes of calculating child support. Father responded, “I’ll have to do my research on that, Judge.” The court allowed Father three more days to do research and “submit something about whether or not this should be considered as a net resource” because Father could have had “access to documentation related to your benefits that would clarify that for all of us.”
8 Father filed a “motion regarding net resources; acknowledgment of service- connected VA disability compensation; primary request for variance from guidelines under Tex. Fam. Code § 154.123 due to equal possession and hardship.” He acknowledged that his VA payments were service-connected disability compensation included in net resources under Section 154.062(b)(5). He also asked the court to “[c]redit any dependent/apportionment benefits for the child dollar-for- dollar against any support obligation.” He attached an unsworn declaration indicating he had “disability-related expenses” of $3,500 per month and also paid direct child expenses of $750 per month during the time that the Child was in his care. The trial court signed a final order obligating Father to pay child support of $794 per month with the first payment due on August 1, 2025. The court found that Father’s net resources were $3,974 per month; the percentage applied to net resources was twenty percent; and the amount of child support was in accordance with the Family Code guidelines. The court included a withholding order so any employer of Father would be ordered to withhold the child support payments from Father’s earnings. After Father requested findings of fact and conclusions of law, the trial court signed findings and conclusions regarding child support consistent with its order.8 The court also found: “34. Regarding Texas Family Code section 154.132, the court did not find that the children were currently receiving periodic benefits as a result of a disability of [Father]. Therefore, no disability-based benefits paid were credited.” 8 However, the court found that Father’s net resources were $3,975 rather than $3,974. Father does not complain about this minor discrepancy.
9 C. No Error Regarding Net Resources Findings, Not Crediting “Dependent Component” of VA Disability Benefits, or Applying Offset Father contends that the trial court failed to segregate the “dependent component” of his VA benefits that were being paid to him or to offset the dependent amount pursuant to Section 154.132, and the evidence was insufficient to support the trial court’s findings regarding net resources and VA benefits.9 The reduction to a guidelines child support amount that is required by Section 154.132 only applies when the child “receives periodic benefits” or the benefits are paid “to or for the child.” Tex. Fam. Code § 154.132(a). Our research suggests that courts have only applied this provision when the disability payment is made to the child or to the support obligee as the child’s representative—not when the payment is made directly to the obligor. See, e.g., In re G.L.S., 185 S.W.3d 56, 57–59 (Tex. App.—San Antonio 2005, no pet.). Here, the record includes some evidence that Father receives a dependent VA disability benefit “directly” and “in addition” to the $3,974 that he receives for his disability. But even if a dependent amount was actually included in the $3,974, as Father suggests on appeal, he would not be entitled to a reduction in child support under Section 154.132(a) or a reduction to his net resources because the trial court could treat the entire payment as Father’s net resources. Cf. Banakar v. Krause, 674 S.W.3d 564, 576–78 (Tex. App.—Houston [1st Dist.] 2023, no pet.) (under similar statute applicable to Social Security benefits, trial court did not err by including payments in obligor’s net resources when obligor received the payments directly; rejecting obligor’s contention that he could deposit the benefits into his credit union 9 We assume without deciding that appellant preserved error or was exempted from doing so for these complaints.
10 account instead of sending the benefits to the obligee and “still subtract the amount of those benefits from his child support obligation”). In other words, Father can’t “have it both ways”—he can’t retain any dependent benefits himself while offsetting his child support obligation by those dependent benefits. See id. at 577. To the extent Father contends on appeal that his payment of $430 to Mother was evidence that he does not retain a dependent disability benefit, his testimony belies this contention. Consistent with the trial court’s finding No. 34, Father did not establish his right to a credit or offset under Section 154.132. The evidence is sufficient to support the trial court’s net-resources finding of $3,974 and the court’s award of $794 in child support. Father cites no authority to support his appellate argument that documentary evidence is required. Cf. Nikolenko v. Nikolenko, No. 01-20-00284- CV, 2022 WL 479988, at *16 (Tex. App.—Houston [1st Dist.] Feb. 17, 2022, pet. denied) (mem. op.) (documentation not required to prove debts in division of marital estate; lack of documentation goes to credibility and weight of testimony, and credibility determination is for trial court to make). Even so, Father conceded that $3,974 was part of his net resources and attached documentary evidence to support the $3,974 amount in his post-hearing motion. Although he asked the trial court to credit him any dependent amount, he provided no testimony or documentation to support a finding that the Child or Mother was receiving a dependent benefit directly based on Father’s disability. Issues 11–13, 16–19, 21, 24, 44, and 46–48 are overruled. D. No Preservation and No Error for Alleged Denial of “Meaningful Hearing” About Dependent Benefits Father contends that the trial court denied him a “meaningful hearing” on whether a dependent benefit was “already being passed through for the child’s
11 benefit,” and the court did not make a “developed finding explaining why” it discounted Father’s evidence of a dependent benefit. As noted above, appellant did not object to the reopening procedure, so he did not preserve any error in the denial of a “meaningful hearing” about dependent benefits. See supra Part I. And as noted in greater detail below, a trial court generally has no duty to make evidentiary findings. See infra Part IV.B. Moreover, the trial court allowed Father to present any evidence he could regarding his disability benefits, and Father did not adduce any evidence at the hearing or in his numerous post-trial filings to show that Mother or the Child received any dependent benefits. He testified that he received the benefits directly. The record does not support Father’s argument that he was denied a meaningful hearing. See Lesem v. Mouradian, 445 S.W.3d 366, 376 (Tex. App.—Houston [1st Dist.] 2013, no pet.) (party was not denied opportunity to present relevant evidence, and he did not articulate what evidence he would have elicited; distinguishing case in which party showed through bill of exceptions that material fact issues were controverted); Nichols v. Catalano, 216 S.W.3d 413, 415 (Tex. App.—San Antonio 2006, no pet.) (record did not support assertion that trial court prevented party from presenting evidence). Issue 23 is overruled. E. No Error to Deny Downward Deviation Father contends that the trial court ignored his evidence of direct support of the Child while she was in his care—such as his providing food, diapers, and milk— and the court denied a downward deviation from the guidelines “without adequately addressing the statutory factors and Appellant’s direct-support evidence.”
12 Parents have a duty to support a child with clothing, food, and shelter. Tex. Fam. Code § 151.001(a)(3). In deciding whether to deviate from the guidelines, a trial court may consider the amount of the obligor’s possession of the child, among other factors. See id. § 154.123(b)(4). The Family Code creates rebuttable presumptions that both the guidelines amount of child support and a standard possession order, as the trial court ordered here, are in a child’s best interest. See Tex. Fam. Code §§ 153.122(a), 153.252(2). Thus, Father’s provision of clothing and food to the Child during periods of possession under a standard possession order does not justify a downward deviation from the guidelines. See In re S.A.D., No. 05-02-01213-CV, 2003 WL 21378256, at *2 (Tex. App.—Dallas June 16, 2003, no pet.) (mem. op.) (trial court abused its discretion by deviating downward from guidelines when court also signed standard possession order; “A standard possession order neither suffices to make the child support guidelines unjust or inappropriate nor justifies the trial court’s reducing the guideline’s predetermined child support amount. Rather, it dictates the opposite.”). The trial court’s findings and conclusions do not support Father’s argument that the court “ignored” Father’s evidence; rather, the court found Father’s evidence unpersuasive to rebut the presumption that the guidelines amount was in the Child’s best interest. Issues 15, 20, and 45 are overruled. F. No Preservation and No Error for Start Date Father contends that the trial court erred by making his first child support payment due on August 1 although he was not awarded VA benefits until August 29. It does not appear from the record that Father preserved error for this complaint. Cf. In re I.J.K., No. 08-22-00055-CV, 2023 WL 3153645, at *11 (Tex. App.—El Paso Apr. 28, 2023, pet. denied) (mem. op.) (party failed to preserve complaint that
13 it was improper to calculate child support arrears based on first day of the month when this procedure conflicted with how employers withhold child support payments from employees’ paychecks). Even if preservation were not required, Father cites no authority for his contention that the trial court could not order him to pay child support for the month of August, effective on the first of the month, because he was not paid his VA benefits until later in the month. His argument is not persuasive. See Bertucci v. Watkins, 709 S.W.3d 534, 542 n.9 (Tex. 2025) (“[I]f the briefing does not make arguments the court finds persuasive, its decision on an issue may reflect that failure.”); see also Kozera v. Velemir, No. 01-17-00290-CV, 2018 WL 6542584, at *5–6 (Tex. App.—Houston [1st Dist.] Dec. 13, 2018, pet. denied) (mem. op.) (appellant waived error due to inadequate briefing for complaint that trial court improperly directed child support payments to be made monthly rather than bi- weekly). Issue 14 is overruled. G. No Preservation and No Error to Include Standard Income Withholding Order Father contends that the trial court’s support order is “internally inconsistent” with an “income withholding order” that identifies appellant as self-employed. The trial court’s judgment includes a statutorily mandated income withholding provision, which would be implied regardless. See Tex. Fam. Code § 154.007. The record also includes an unsigned “Income Withholding for Support (IWO)” form that identifies Father as self-employed. It does not appear from the record that Father complained to the trial court about income withholding, so he did not preserve error. Cf. In re D.Z., 583 S.W.3d 284, 297 (Tex. App.—Houston [14th Dist.] 2019, no pet.) (no error preserved for
14 complaint that attorney’s fees were made subject to income withholding as child support). Regardless, Father cites no authority for his contentions of error and harm, and his argument is not persuasive. See Tex. Fam. Code § 154.007; see also Bertucci, 709 S.W.3d at 542 n.9. Issue 22 is overruled. III. U NDER-THREE POSSESSION ORDER In Issues 34–36, 38–39, and 43, Father complains about the trial court’s possession order that applied until the Child reached three years of age, at which point the court ordered a standard possession order. See Tex. Fam. Code § 153.254(a), (d). The Child reached the age of three while this appeal was pending, so the under-three possession order is no longer in effect. Thus, Father’s complaints about the under-three order are moot. See In re K.L.M., No. 05-25-00829-CV, 2026 WL 1149319, at *6 n.2 (Tex. App.—Dallas Apr. 28, 2026, no pet.) (mem. op.); see also, e.g., Sexton v. Sexton, No. 14-25-00331-CV, 2026 WL 879351, at *2 (Tex. App.— Houston [14th Dist.] Mar. 31, 2026, pet. denied) (mem. op.) (challenge to possession order is moot when child reaches age of majority because possession order is “no longer in effect”). Issues 34–36, 38–39, and 43 are overruled. IV. C ONSERVATORSHIP In Issues 26–33, 37, 41–42, and 49, Father contends that the trial court erred by allocating exclusive parental rights to Mother because doing so conflicts with the trial court’s findings that both parents were fit or other allocations of parental rights; the court failed to make specific factual findings explaining “why” it allocated
15 certain rights to Mother; and the court erred by finding that it did not limit Father’s parental rights. A. Background In its final order, the trial court appointed Father and Mother joint managing conservators of the Child. The court gave Mother the exclusive rights to: • designate the primary residence of the Child; • enroll the Child in school; • receive and give receipt for periodic payments for the support of the Child; and • file and claim income tax and an income tax credit for the Child. The court gave each parent the right to consent to psychiatric and psychological treatment of the Child and the right to consent to invasive medical, dental, and surgical procedures, but the court made Father’s rights “subject to the agreement of” Mother while her rights are “subject to prior consultation with” Father. The court gave each parent a right to make decisions concerning the Child’s education. And the court ordered that the primary residence of the Child shall be within Harris County and contiguous counties so long as Father resides in Harris County or a contiguous county. The court found that each of its conservatorship orders was in the best interest of the Child. Upon Father’s request, the court filed separate findings of fact and conclusions of law, again finding that the parenting plan established by the court regarding conservatorship was in the Child’s best interest. Regarding its under-three possession order, the court also found: • Frequent contact with Father will promote the Child’s ability to maintain healthy attachments to both parents.
16 • Both parents are physically, medically, emotionally, economically, and socially capable of caring for the Child during their periods of possession. • Both parents are available and willing to personally care for the Child. The court concluded, “13. The Court did not limit the rights and duties of either conservator. Therefore, the court need not make written findings on that issue. Tex. Fam. Code § 153.072.” B. Division of Parental Rights Without Evidentiary Findings When a trial court appoints joint managing conservators, the court must “designate the conservator who has the exclusive right to determine the primary residence of the child” and may “establish a geographic area within which the conservator shall maintain the child’s primary residence.” Tex. Fam. Code § 153.134(b)(1). The court must also “allocate between the parents, independently, jointly, or exclusively, all of the remaining rights and duties of a parent as provided by Chapter 151.” Id. § 153.134(b)(4); see also id. § 153.071 (when both parents appointed conservators, “the court shall specify the rights and duties of a parent that are to be exercised: (1) by each parent independently; (2) by the joint agreement of the parents; and (3) exclusively by one parent”). As relevant here, parents have rights to: • designate the school the child will attend and to enroll the child in the school; • make decisions concerning the child’s education; • receive and give receipt for payments for the support of the child; and • consent to the child’s medical and dental care, and psychiatric, psychological, and surgical treatment.
17 Id. § 151.001(a)(6), (8), (10), (11). A court “may limit the rights and duties of a parent appointed as a conservator if the court makes a written finding that the limitation is in the best interest of the child.” Id. § 153.072. The best interest of the child is always the primary consideration when determining issues of conservatorship. Id. § 153.002(a). Because a trial court has a duty to allocate parental rights between joint managing conservators under these statutes, usually one parent is given greater powers than the other. See Wadhwa v. Wadhwa, 720 S.W.3d 169, 180 (Tex. App.— Houston [14th Dist.] 2025, no pet.) (citing Albrecht v. Albrecht, 974 S.W.2d 262, 265 (Tex. App.—San Antonio 1998, no pet.)). Indeed, a trial court must allocate an exclusive right to designate the primary residence. See Tex. Fam. Code § 153.134(b)(1). Thus, the allocation of some exclusive rights to one parent rather than another does not conflict with the trial court’s findings that both parents are fit. Contrary to appellant’s suggestion, no specific finding of a safety concern or unfitness is required for the trial court to allocate exclusive rights or limit a joint managing conservator’s rights. See id. §§ 153.071, 153.072, 153.134(b). Father complains about the trial court’s failure to show or explain in its findings of fact and conclusions of law “why” the court allocated certain rights to Mother and made a geographical restriction on the primary residence. Father waived most of these complaints by failing to notify the trial court of incomplete findings or to request additional findings. See, e.g., Henry v. Cook, No. 14-25-00089-CV, 2026 WL 1396084, at *1 (Tex. App.—Houston [14th Dist.] May 19, 2026, no pet.) (mem. op.); Villalpando v. Villalpando, 480 S.W.3d 801, 809–10 (Tex. App.—Houston [14th Dist.] 2015, no pet.).10 10 Our review of the record suggests that after the trial court issued its findings, Father only complained about the inadequacy of findings pertaining to child support, the right to determine the
18 Regardless of any waiver, Father’s complaints are about the trial court’s failure to make “evidentiary” findings, which the trial court had no duty to make. See Bushlow v. Bushlow, No. 14-22-00521-CV, 2023 WL 10949868, at *2 (Tex. App.—Houston [14th Dist.] Apr. 9, 2023, no pet.) (mem. op.) (request for additional findings that does “no more than request explanations of the court’s ruling” are evidentiary, which are not required by Rule of Civil Procedure 298) (quoting Dura- Stilts Co. v. Zachry, 697 S.W.2d 658, 661 (Tex. App.—Houston [1st Dist.] 1985, writ ref’d n.r.e.)); In re Marriage of Jameson, No. 07-02-0476-CV, 2004 WL 237829, at *2 (Tex. App.—Amarillo Feb. 9, 2004, pet. denied) (mem. op.) (proposed findings that “simply address how or why the trial court resolved the ultimate fact in a particular way are merely evidentiary and need not be entered”). A finding that the trial court’s conservatorship determinations are in the best interest of the child is sufficient; no additional findings are required. See Mitchell v. Young, No. 02-24-00292-CV, 2025 WL 1909327, at *8–9 (Tex. App.—Fort Worth July 10, 2025, no pet.) (mem. op.) (overruling parent’s complaint that trial court’s findings failed to “explain why” court allocated exclusive rights to other parent because “further findings by the court regarding its best-interest determination are not required under Section 153.072”); Davenport v. Davenport, No. 01-15-01031- CV, 2016 WL 7011406, at *5 (Tex. App.—Houston [1st Dist.] Dec. 1, 2016, no pet.) (mem. op.) (trial court’s best interest finding “addressed the ultimate or controlling fact essential to the claim and necessary to the judgment,” so “[a]ny other findings would be merely evidentiary”); see also In re Marriage of Jameson, 2004 WL Child’s primary residence, and the “tax dependency” allocation. These are the only challenges that Father arguably preserved.
19 237829, at *2 (overruling parent’s complaint about absence of findings illustrating “how or why” trial court named other parent custodial joint managing conservator).11 Father suggests further that his right to make decisions concerning the Child’s education is “internally inconsistent” with Mother’s right to enroll the Child in school. But the court’s judgment can be construed as a whole to harmonize and give effect to both provisions. See Constance v. Constance, 544 S.W.2d 659, 660 (Tex. 1976) (“Judgments, like other written instruments, are to be construed as a whole toward the end of harmonizing and giving effect to all the court has written.”). Mother’s right to enroll the Child is school is more specific than both parents’ general right to make educational decisions. See Huffman v. Huffman, 161 Tex. 267, 272 n.3, 339 S.W.2d 885, 889 n.3 (1960) (more specific findings in the judgment control over general findings). Thus, Father’s right is tempered and limited by Mother’s right to enroll the Child in school. See Rogers v. Rogers, No. 01-15-00224- CV, 2016 WL 3162299, at *4–5 (Tex. App.—Houston [1st Dist.] June 2, 2016, no pet.) (mem. op.) (no conflict when father had right to determine primary residence and mother had right to enroll in school, and both parents had right to make educational decisions; father’s residence right “naturally serve[s] as a limitation on the area in which the children will be enrolled in school” and mother’s right to make educational decisions was “tempered by” father’s same right). Finally, we assume without deciding that the trial court’s conclusion of law No. 13 was erroneous, and the court was required to make best interest findings for 11 The Legislature sometimes requires evidentiary findings. See, e.g., Tex. Fam. Code § 153.258 (when possession order varies from standard possession order, “the court shall state in writing the specific reasons for the variance”); id. § 154.130(a)(3), (b) (when child support varies from guidelines, trial court “shall state . . . the specific reasons” for the variance). Section 153.072 includes no similar specificity requirement. See id. § 153.072.
20 its allocation of exclusive rights to Mother.12 But the trial court did find that its allocations of parental rights were in the Child’s best interest. And Father does not challenge the sufficiency of the evidence for those findings. Thus, Father has not shown how the trial court’s erroneous conclusion probably caused the rendition of an improper judgment or prevented him from presenting the case to this court. See Tex. R. App. P. 44.1(a); see also BMC Software Belgium, N.V. v. Marchand, 83 S.W.3d 789, 794 (Tex. 2002) (“If the reviewing court determines a conclusion of law is erroneous, but the trial court rendered the proper judgment, the erroneous conclusion of law does not require reversal.”). Father’s Issues 26–33, 37, 41–42, and 49 are overruled. V. C UMULATIVE ERROR In Issues 10, 25, 40, and 50, Father complains of cumulative error regarding his four categories: procedural, child support, conservatorship and possession, and inadequate or conflicting findings. As noted above, we assume error in the trial court’s conclusion that it did not limit Father’s parental rights, but any such error was harmless because the trial court made the statutory best interest findings. See supra Part IV.B. We find no other error. The cumulative error doctrine requires multiple errors. See, e.g., Jones v. Lurie, 32 S.W.3d 737, 745 (Tex. App.—Houston [14th Dist.] 2000, no pet.). Father 12 See Mitchell v. Young, No. 02-24-00292-CV, 2025 WL 1909327, at *8–9 (Tex. App.— Fort Worth July 10, 2025, no pet.) (mem. op.) (Section 153.072 satisfied by best interest finding when trial court ordered joint managing conservatorship but allocated some exclusive rights to one parent); see also In re D.L.N., 609 S.W.3d 237, 246–47 (Tex. App.—Texarkana 2020, no pet.) (analyzing best interest finding under Section 153.072 when trial court awarded some exclusive rights to one parent); Guion v. Guion, 597 S.W.3d 899, 906–08 (Tex. App.—Houston [1st Dist.] 2020, no pet.) (citing Section 153.072 for support of trial court’s geographical restriction on child’s primary residence); In re D.R.S., 138 S.W.3d 467, 470 & n.9 (Tex. App.—Houston [14th Dist.] 2004, pet. denied) (noting that allocation of parental rights among joint managing conservators is expressly allowed by statute if court makes Section 153.072 best interest finding).
21 has not shown multiple errors, so he cannot show cumulative error. See Bott v. Bott, 962 S.W.2d 626, 631 (Tex. App.—Houston [14th Dist.] 1997, no pet.) (declining to consider overruled points to determine cumulative error when several of those points were unpreserved and only one point involved error that was harmless); see also Fisher v. Kawasaki Heavy Indus., Ltd., No. 13-15-00364-CV, 2017 WL 2817662, at *8 (Tex. App.—Corpus Christi–Edinburg June 29, 2017, no pet.) (mem. op.) (“Because we found no errors with regard to Fisher’s first three issues, and found harmless error under Fisher’s fourth issue, we need not undertake a cumulative-error analysis in this case.”). Father’s Issues 10, 25, 40, and 50 are overruled. VI. C ONCLUSION Having overruled each of Father’s fifty issues, we affirm the trial court’s judgment. /s/ Ken Wise Justice Panel consists of Justices Wise, Jewell, and Hart.
22 A PPENDIX: I SSUES Category 1: Procedural and Due Process Issue 1. Whether the trial court denied due process by structuring the final trial in a manner that materially limited Appellant’s opportunity to present his case. Issue 2. Whether the trial court committed reversible legal error by reopening the evidence under Texas Rule of Civil Procedure 270 for the limited purpose of altering child support after trial. Issue 3. Whether the trial court improperly limited the scope of the reopened hearing to support while excluding Appellant’s competing proposed order and related objections. Issue 4. Whether the reopening was based on evidence that was not truly new, but merely a later-occurring development from a subject already disclosed at trial. Issue 5. Whether the trial court misapplied Rule 270 by reopening evidence without giving Appellant a balanced opportunity to develop the related legal issues. Issue 6. Whether the trial court improperly curtailed Appellant’s attempt to explain the effect of the benefit and the dependent component. Issue 7. Whether the reopened hearing produced a legal—not discretionary— support question requiring de novo review. Issue 8. Whether the court failed to resolve the governing legal question before incorporating the new income into the final support calculation. Issue 9. Whether the sequence of reopening, legal uncertainty, and immediate entry of judgment produced harmful procedural error. Issue 10. Whether the cumulative procedural errors require reversal and rendition rather than remand. Category 2: Child Support Issue 11. Whether the trial court erred by treating the entire VA payment stream as Appellant’s child-support resources without segregating the child- related dependent component.
23 Issue 12. Whether the trial court failed to apply Texas Family Code section 154.132 to disability-based benefits being paid on behalf of the child. Issue 13. Whether legally sufficient evidence supports the finding that Appellant’s net resources were exactly $3,975.00 per month. Issue 14. Whether the trial court improperly used a support start date of August 1, 2025 even though the reopened-hearing testimony placed Appellant’s first VA check on August 29, 2025. Issue 15. Whether the trial court denied a downward deviation without adequately addressing the statutory factors and Appellant’s direct- support evidence. Issue 16. Whether the trial court failed to credit Appellant’s admitted $430 payment to Appellee when evaluating the support and disability-benefit issues. Issue 17. Whether the trial court conflated the concepts of non-garnishability and net-resource inclusion without resolving the legal and factual distinctions relevant to this case. Issue 18. Whether the trial court erred by denying section 154.132 credit while simultaneously acknowledging testimony that the child had been added to Appellant’s benefits. Issue 19. Whether the trial court failed to require competent documentary support before fixing a precise support amount and medical-support reimbursement. Issue 20. Whether the trial court’s denial of deviation ignored evidence that Appellant directly provides food, diapers, milk, and daily care during his possession periods. Issue 21. Whether the trial court improperly equated gross benefit testimony with net resources without record evidence of the deductions or adjustments necessary to reach a lawful chapter 154 calculation. Issue 22. Whether the trial court entered a support order that is internally inconsistent with the Income Withholding Order’s designation of Appellant as self-employed. Issue 23. Whether the trial court denied Appellant a meaningful hearing on whether the child-related add-on was already being passed through for the child’s benefit.
24 Issue 24. Whether no competent evidence supports the precise monthly child- support figure of $794.00. Issue 25. Whether the cumulative child-support errors require reversal and rendition of a corrected support order. Category 3: Conservatorship and Possession Issue 26. Whether the trial court’s allocation of exclusive and superior rights to Appellee is irreconcilable with findings that both parents are capable and that the child benefits from frequent contact with both parents. Issue 27. Whether the exclusive right to designate the child’s primary residence was unsupported by specific findings distinguishing two fit parents. Issue 28. Whether the geographic restriction to Harris County and contiguous counties—and the lift provision tied to Appellant’s residence—was unsupported by the findings actually made. Issue 29. Whether the final order’s exclusive school-enrollment provision conflicts with the findings and with the broader joint-managing- conservatorship structure. Issue 30. Whether the trial court erred by awarding Appellee the exclusive right to receive and disburse support funds while simultaneously finding that it did not limit the rights and duties of either conservator. Issue 31. Whether the trial court erred by granting Appellee the exclusive right and duty to claim the child for income-tax purposes without findings supporting that one-sided allocation. Issue 32. Whether the allocation of invasive-medical and psychological- treatment authority to Appellee was unsupported by the findings and inconsistent with the finding that both parents are capable caregivers. Issue 33. Whether the final order’s educational-rights allocation is internally inconsistent and unsupported because it gives Appellant an independent educational right while simultaneously empowering Appellee to control actual enrollment. Issue 34. Whether the custom under-three possession schedule was unsupported by the findings to the extent it materially reduced Appellant’s time despite findings favoring frequent and continuing contact.
25 Issue 35. Whether the condition that all under-three overnights occur at the paternal grandmother’s residence was unsupported by any specific finding of necessity. Issue 36. Whether the final order’s automatic switch to an expanded Standard Possession Order at age three is incompatible with the findings that there was no variation from the SPO. Issue 37. Whether the final order’s use of Appellee’s school-enrollment control and geographic control effectively nullifies the order’s repeated statements favoring shared parenting. Issue 38. Whether the possession findings regarding routine, proximity, and the lack of negative impact from third parties undercut the need for the specific restrictions the order imposed on Appellant’s possession. Issue 39. Whether the final order’s statement that nothing in the order supersedes any protective order or condition of bond, probation, or parole highlights the absence of specific findings connecting those concerns to the possession terms entered. Issue 40. Whether the cumulative conservatorship-and-possession errors require reversal and rendition of a conservatorship structure consistent with the court’s affirmative findings. Category 4: Findings Issue 41. Whether Finding No. 13—that the court did not limit the rights and duties of either conservator—is legally irreconcilable with the exclusive-right allocations in the final order. Issue 42. Whether Findings Nos. 16–19 internally contradict Finding No. 13 by expressly acknowledging exclusive rights after stating that no rights were limited. Issue 43. Whether Finding No. 26(d)—that the court did not order any variation from the Standard Possession Order—is contradicted by both the findings and the final order creating a custom under-three schedule. Issue 44. Whether Finding No. 27—that the child support ordered is in accordance with chapter 154—is unsupported in light of the unresolved dependent-component, credit, and timing issues shown in the reporter’s record.
26 Issue 45. Whether Finding No. 28—that Appellant failed to present evidence sufficient to rebut the guidelines presumption—ignores the direct- support testimony the court heard. Issue 46. Whether Finding No. 31—that Appellant’s net resources were $3,975.00 per month—is unsupported by the hearing evidence. Issue 47. Whether Finding No. 33 improperly treats the entire VA disability payment as Appellant’s net resources while failing to reconcile the child-dependent component discussed at hearing. Issue 48. Whether Finding No. 34—that the child was not currently receiving periodic benefits as a result of Appellant’s disability—is contradicted by the reopened-hearing testimony. Issue 49. Whether the findings fail to supply the specific best-interest reasoning necessary to support the exclusive tax, school, residence, and support- control allocations made in the final order. Issue 50. Whether the cumulative contradictions between the findings, the reporter’s record, and the final order require reversal and rendition rather than remand.
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