In the Interest of M.G., a child — Memorandum Opinion by Justice Wise

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.)

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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

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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.

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• 	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.

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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.

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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.

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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.

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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.

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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.

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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.