Full Opinion

In the Court of Appeals Second Appellate District of Texas at Fort Worth ___________________________ No. 02-25-00358-CV ___________________________ ZACHARY WAYNE WHITE AND ALAINA WHITE, Appellants V. AJ ESTATES, LLC, Appellee On Appeal from the 467th District Court Denton County, Texas Trial Court No. 24-5962-467 Before Sudderth, C.J.; Womack and Wallach, JJ. Memorandum Opinion by Justice Wallach MEMORANDUM OPINION This is an appeal from a final summary judgment in favor of Appellee in an action to quiet title to a residential property. We will affirm. I. Background Because of the nature of the disposition of this case, this background statement is general in nature with more specifics being laid out as necessary under the analysis section below. Appellants are Zachary Wayne White (Mr. White) and Alaina Michelle White (Ms. White) (collectively the Whites or Appellants). They were self-represented in the trial court and remain so on appeal. The Whites executed a promissory note and deed of trust securing the note with respect to the property in question. AJ Estates LLC (Appellee) purchased the property at a non-judicial foreclosure sale on September 5, 2023. The Whites refused to vacate the property after Appellee purchased it and engaged in conduct that Appellee alleged constituted a cloud on its title to the property. Appellee filed the underlying action to remove the cloud on title, confirm its ownership interest, and obtain an order for possession of the property. Appellee filed a traditional motion for summary judgment, and the Whites responded. Appellee filed a motion to strike the response. The trial court purportedly granted the motion to strike as to Ms. White but denied it as to Mr. White. The trial court granted the summary judgment motion. The Whites filed a Motion for New Trial that was overruled by operation of law. 2 II. Standards of Review and Applicable Legal Principles A. Inadequate Briefing We summarized the law regarding briefing requirements in In re J.D.: Rule 38.1 of the Texas Rules of Appellate Procedure contains specific requirements for an appellant’s brief. See Tex. R. App. P. 38.1. To comply with Rule 38.1, an appellant’s brief must, among other things, “contain a clear and concise argument for the contentions made, with appropriate citations to authorities and to the record.” Tex. R. App. P. 38.1(i). Merely uttering brief, conclusory statements unsupported by citation to legal authorities does not satisfy briefing requirements. In re A.N.G., 631 S.W.3d 471, 476 (Tex. App.—El Paso 2021, no pet.). Indeed, “[f]ailure to cite legal authority or provide substantive analysis of the legal issue presented results in waiver of the complaint.” Valadez v. Avitia, 238 S.W.3d 843, 845 (Tex. App.—El Paso 2007, no pet.). Similarly, when an appellant fails to cite the record to support an appellate issue, the appellant waives that complaint. Floyd v. Floyd, No. 02-23-00193-CV, 2024 WL 3714176, at *2 (Tex. App.—Fort Worth Aug. 8, 2024, no pet.) (mem. op.). No. 02-24-00515-CV, 2025 WL 2810523, at *2 (Tex. App.—Fort Worth Oct. 2, 2025, no pet.) (mem. op.). Briefing requirements apply to self-represented litigants just as they apply to licensed attorneys; all must comply with the applicable rules of procedure. Id. In reviewing for briefing waiver, we are to construe briefs liberally so as not to waive the right to appellate review. Id. But it is not this court’s responsibility to identify “possible trial court error, search[ ] the record for facts favorable to a party’s position, or conduct[ ] legal research to support a party’s contentions.” In re J.O.A.M., Nos. 01-23-00691-CV, 01-23-00692-CV, 2024 WL 1169432, at *23 (Tex. App.— Houston [1st Dist.] Mar. 19, 2024, no pet.) (mem. op.); In re J.D., 2025 WL 2810523, at 3 *2. “Were we to engage in such activities, we would be abandoning our role as judges and taking on the role of advocate for that party.” In re J.O.A.M., 2024 WL 1169432, at *23 (citing Valadez, 238 S.W.3d at 845). B. Preservation of Error Again, looking to our opinion in In re J.D., To preserve a complaint for appellate review, a party must present to the trial court a timely request, objection, or motion that states the specific grounds for the desired ruling, if not apparent from the request’s, objection’s, or motion’s context. Tex. R. App. P. 33.1(a)(1)(A); see ETC Mktg., Ltd. v. Harris Cnty. Appraisal Dist., 528 S.W.3d 70, 74 (Tex. 2017). If a party fails to do this, error is not preserved. Bushell v. Dean, 803 S.W.2d 711, 712 (Tex. 1991) (op. on reh’g). The objecting party must also get a ruling—either express or implied—from the trial court. Tex. R. App. P. 33.1(a)(2)(A), (b); see Lenz v. Lenz, 79 S.W.3d 10, 13 (Tex. 2002). If the trial court refuses to rule, the party preserves error by objecting to that refusal. Tex. R. App. P. 33.1(a)(2)(B). If the trial court does not rule and the party does not object to the refusal to rule, error is not preserved. Id. 2025 WL 2810523, at *3. C. Summary Judgment Standards of Review1 We summarized the standards of review for a traditional summary judgment in MVP Fort Worth Taylor, LLC v. Roy, 1 Appellee filed its motion for summary judgment before 2026, so the 2026 amendments to Texas Rule of Civil Procedure 166a do not apply. Supreme Court of Texas, Final Approval of Amendments to Rule 166a of the Texas Rules of Civil Procedure, Misc. Docket No. 26-9012 (Feb. 27, 2026) (applying amendments to motions “filed on or after March 1, 2026”). 4 We review a summary judgment de novo. Energen Res. Corp. v. Wallace, 642 S.W.3d 502, 509 (Tex. 2022); City of Richardson v. Oncor Elec. Delivery Co., 539 S.W.3d 252, 258–59 (Tex. 2018); Mann Frankfort Stein & Lipp Advisors, Inc. v. Fielding, 289 S.W.3d 844, 848 (Tex. 2009); Fontana Evolution, LLC v. SCP Distribs., LLC, No. 02-22-00211-CV, 2023 WL 308176, at *3 (Tex. App.—Fort Worth Jan. 19, 2023, no pet.) (mem. op.). A party moving for traditional summary judgment must conclusively establish that it is entitled to judgment as a matter of law. See Tex. R. Civ. P. 166a(a), (b), (c); Energen Res. Corp., 642 S.W.3d at 509; City of Richardson, 539 S.W.3d at 258–59; Mann Frankfort Stein & Lipp Advisors, 289 S.W.3d at 848. Unless it carries this burden, the non-movant has no obligation to even respond. Energen Res. Corp., 642 S.W.3d at 509. When, as here, the trial court does not specify a basis for its summary judgment, we must affirm if any basis presented to the trial court has merit. Fontana Evolution, 2023 WL 308176, at *3. No. 02-23-00060-CV, 2024 WL 3529432, at *2 (Tex. App.—Fort Worth July 25, 2024, no pet.) (mem. op.). We consider the evidence presented in the light most favorable to the nonmovant, crediting evidence favorable to the nonmovant if reasonable jurors could, and disregarding evidence contrary to the nonmovant unless reasonable jurors could not. Mann Frankfort Stein & Lipp Advisors, Inc., 289 S.W.3d at 848. We indulge every reasonable inference and resolve any doubts in the nonmovant’s favor. 20801, Inc. v. Parker, 249 S.W.3d 392, 399 (Tex. 2008). III. Analysis Appellants raise eight issues on appeal, numbered one through nine but omitting number four. The first three issues deal with procedural complaints: 1. Did the trial court render a summary judgment void by granting it without the proof of notice required by the Denton County 5 Summary-Judgment Instructions and without an opportunity to be heard, contrary to Rule 166a(c) and due process? (CR 464, 946.) [footnote omitted] 2. Did the trial court violate due process by canceling the Reconsideration hearing before its noticed date for “failure to appear” and refusing to hear a new-trial motion? (CR 840, 963) 3. Is the judgment void where the court: (a) first inserted the new dispositive finding “Defendants have not pled any affirmative defense” in the final order, and (b) failed to serve it, effectively concealing the finding? (CR 893–895; (CR-SUPP 6–10) The last five issues are merits-related: [4. Omitted by Appellants] 5. Did [Appellee] fail to conclusively establish superior title . . . ? (CR 486-497, 439-440.) 6. Was the foreclosure void because the obligation had been discharged by tender under[2] Tex. Bus. & Com. Code §§ 3.310, 3.420, and 3.603 before the sale, and no competent evidence refuted discharge? (CR 534–566, 439-440.) 7. Was the deed of trust void ab initio . . . ? (CR 512–513.) 8. Was the sale void because the substitute trustee lacked neutrality . . . ? (CR 567–577, 439–440 CR-SUPP 6-10). 9. Did constructive notice recorded before the sale defeat [Appellee’s] bona fide-purchaser claim? (CR 486-566.) 2 The Whites’ brief asserts that the debt had been discharged and that “a related federal wrongful-foreclosure action [brought by Mr. White] remained pending.” The federal suit was resolved against Mr. White. White v. Fifth Third Bank, Nat’l Ass’n, No. 4:23-CV-00847, 2025 WL 2591575 (E.D. Tex. Aug. 16, 2025), report and recommendation adopted, No. 4:23-CV-00847, 2025 WL 2663660 (E.D. Tex. Sept. 17, 2025), aff’d sub nom. White v. Fifth Third Bank, No. 25-40647, 2026 WL 1135449 (5th Cir. Apr. 27, 2026). 6 A. Issue One The Whites complain of being deprived of due process because of inadequate notice of the two summary judgment hearings in question pursuant to Texas Rule of Civil Procedure 166a(c) and the Denton County Summary Judgment Instructions. Contrary to the Whites’ argument that inadequate notice renders a summary judgment void, inadequate notice is a non-jurisdictional defect. May v. Nacogdoches Mem. Hosp., 61 S.W.3d 623, 626 (Tex. App.—Tyler 2001, no pet.); White v. Wah, 789 S.W.2d 312, 319 (Tex. App.—Houston [1st Dist.] 1990, no writ). If a party receives notice that is untimely but sufficient to enable the party to attend the summary judgment hearing, the party must file a motion for continuance or raise the complaint of late notice in writing, supported by affidavit evidence, and raise the issue before the trial court considers the motion. May, 61 S.W.3d at 626. Here, the Whites admit that they had notice of the first submission date and that they showed up in the courtroom. However, no hearing was held since the matter was set for submission, not hearing. Regardless, they did not file a motion for continuance or an objection to inadequate notice. As a result, their complaint was not preserved for review. Id. Additionally, the party complaining of inadequate notice of a summary judgment hearing must show harm to obtain relief. Tivoli Corp. v. Jewelers Mut. Ins. Co., 932 S.W.2d 704, 710 (Tex. App.—San Antonio 1996, writ denied) (holding that where party did not give 21 days’ notice for summary judgment hearing but rescheduled the hearing with 25 days’ notice, no harm was demonstrated). 7 Here, although the clerk’s record does not reflect a motion for summary judgment having been filed yet, Appellee’s first summary judgment hearing was set by notice signed by Appellee’s counsel on October 8, 2024, to be heard by submission on November 7, 2024, at 10:00 AM.3 Summary judgments do not require an in-person hearing but may be considered by written submission. Martin v. Martin, Martin & Richards, Inc., 989 S.W.2d 357, 359 (Tex. 1998). Notice of hearing or written submission of a summary judgment motion, however, is required, although it is not jurisdictional. Id. The Whites contend that this notice was insufficient because it did not explain the process of written submission versus a hearing, but they are held to the same standards as licensed attorneys and are required to be familiar with and to comply with all applicable laws and rules of procedure. Mansfield State Bank v. Cohn, 573 S.W.2d 181, 184–85 (Tex. 1978); Barrientos v. Barrientos, 675 S.W.3d 399, 404 (Tex. App.—Eastland 2023, pet. denied). Appellants appeared in person at the time and place designated in the notice, but neither opposing counsel nor the court showed up, as would be expected from a licensed attorney for a summary judgment being handled by submission. 3 Interestingly, the clerk’s record reflects that the Whites filed a Response to Appellee’s Motion for Summary Judgment on October 16, 2024, (almost thirty days before it was supposedly filed), but only Mr. White signed it. Appellee filed a Response to the White’s Response. Also interestingly, Appellee filed a Motion to Strike this Response because, among other reasons, Ms. White had not signed it and Mr. White could not represent her since he was not licensed to practice law. The Whites responded to this Motion to Strike on November 6, 2024. The Whites filed and served their “Response to [Appellee’s] Response to Motion [for] Summary Judgment” on November 8, 2024 and attached multiple exhibits. 8 However, Appellee’s motion—which is not in the record—was not considered. No judgment was entered based on that submission. Assuming error was present, no harm was demonstrated. Tivoli, 932 S.W.2d at 710.4 The clerk’s record reflects that Appellee’s Motion for Summary Judgment was filed on November 14, 2024, with service on Mr. White electronically through the electronic filing manager and on Ms. White at her residence address by mail. On November 18, 2024, Appellee’s attorney electronically served and filed a “Notice of Hearing” on Plaintiff’s Motion for Summary Judgment, setting it for submission on December 13, 2024, at 9:00 a.m. in the 467th District Court of Denton County. 5 On December 2, 2024, the Whites timely filed another “Response in Opposition to [Appellee’s] Motion for Summary Judgment” (second response) and served it through the electronic record document service on Appellee’s counsel. See Fuller v. City of Waco Police Dep’t, No. 13-22-00615-CV, 2023 WL 5487370, at *2 (Tex. App.—Corpus Christi–Edinburg Aug. 24, 2023, no pet.) (mem. op.) (holding that the party opposing a traditional motion for summary judgment may file and serve opposing 4 Appellants also complain that they were not served with Appellee’s motion for summary judgment before the hearing. However, as with their notice argument, since the court did not rule on the motion for summary judgment at this setting, no harm is demonstrated. See Smith v. Erhard, 715 S.W.2d 707, 711 (Tex. App.—Austin 1986, writ ref’d n.r.e) (holding that reversible error is not present where the record does reflect a ruling by the trial court). 5 The notice states that it was also sent to the Whites by certified mail. 9 affidavits or other written response not later than seven days before the hearing on the motion, except on leave of court); see also Tex. R. Civ. P. 166a(c)). Additionally, this second response was signed by both of the Whites pursuant to Rule 21(7)(f) by typing their names and an “/s/.” See Tex. R. Civ. P. 21(7)(f). Despite the fact that the Whites’ second response was signed electronically by both of them, on December 10, 2024, Appellee filed another Motion to Strike contending, among other things, that Ms. White had not signed the response and that Mr. White could not sign for her since he was not licensed to practice law. On December 23, 2024, the court signed an order stating it was the court’s “opinion” that Appellee’s “Motion to Strike” as to Ms. White “should be . . . [g]ranted” but denied as to Mr. White. The “order” did not actually order Ms. White’s second response stricken and it gave no rationale. But given the arguments raised in the motion to strike, the only interpretation of the order that would justify striking Ms. White but not Mr. White from the response would be that Mr. White was not competent to sign for her since he is not an attorney. To the extent that this constituted an actual order, the trial court erred since Ms. White’s signature was on the second response in compliance with Rule 21(7)(f). On December 23, 2024, the court coordinator sent an email to the Whites and Appellee’s attorney purporting to communicate the “Judge’s Ruling” on Appellee’s Motion for Summary Judgment. The email opened with the coordinator advising the parties that the matter was set on the court order entry docket for January 24, 2025, at 10 8:30 a.m. via Zoom. The email had the typed initials “dj” (presumably for Derbha Jones, the presiding judge) at the end of the purported ruling that said The Court considered Plaintiffs MSJ by submission. After review of the pleadings, responses, and admitted evidence the Court finds that the Plaintiff’s MSJ should be GRANTED as to both Defendants, the case should be dismissed with prejudice, and IT IS SO ORDERED. Attorney for Plaintiff shall draft the order accordingly and this matter will be set on the Court’s order entry docket by the Court coordinator. This email ruling will be filed with the clerk’s as part of the Court record. dj The coordinator’s email did not constitute a final judgment. First, it did not even constitute an order because it was not signed in conformity with Rule 21(7)(f)—there is no name with an “/s/.” Second, it expressly set the matter for the court’s order entry docket, meaning the court anticipated another final order to be entered. Finally, there is no “finality” language. See In re C.K.M., 709 S.W.3d 613, 616–19 (Tex. 2025) (for a general discussion of finality requirements for judgment in cases disposed of without a conventional trial on the merits).6 According to the Denton County Case Detail, the 6 This “order,” on its face, does not comport with the pleadings and motion for summary judgment. Granting the plaintiff’s (Appellee’s) motion for summary judgment would not result in a dismissal with prejudice. Mr. White raised this discrepancy with the court coordinator and counsel by email dated December 30, 2024. The coordinator responded to Mr. White and counsel that no hearing would be necessary for order entry; rather, she instructed them to submit a proposed order “granting the MSJ only—no dismissal and the parties can proceed accordingly.” Also, the Whites complain that this email “order” did not contain language found in the final judgment entered on May 14 that “Defendants have not pled any affirmative defense.” This email was not a final order. It was interlocutory in nature and subject to the court’s right to change or rescind it as long as the court’s plenary power remained. Watanbe v. Summit Path Partners, LLC, 650 S.W.3d 112, 134 (Tex. App.—Houston [1st Dist.] 2021, no pet.). In fact, the court 11 January 24, 2025 Order Entry hearing was passed, noting “no hearing wanted at this time.” On January 27, 2025, the Whites filed their “Response to [Appellee’s] Motion to Strike and Reply to [Appellee’s] Response to Defendants Response to Motion for Summary Judg[ ]ment.” Apparently believing that the court had granted the motion for summary judgment, on January 27, 2025, the Whites filed their Motion to Reconsider Summary Judgment. Then, on March 12, 2025, the Whites gave notice that a hearing was going to be conducted in person on their Motion to Reconsider on June 25, 2025.7 This was followed on April 4, 2025, by Appellee’s filing its Motion for Entry of Judgment. Appellee then set the Motion for Judgment by Zoom hearing on April 17, 2025, at 9:00 a.m. On April 30, 2025, the Whites filed their Supplement to Motion for Reconsideration and Preservation of Evidence with additional evidence, asking the court for permission to supplement the summary judgment record and that the court defer ruling on the Plaintiff’s Motion for Entry of Judgment until the scheduled June coordinator’s email told Mr. White and counsel to submit an order granting the summary judgment with “no dismissal.” In this case, the court’s final summary judgment was not signed until May 14, 2025, which started the clock running on the expiration of the court’s plenary power. According to the Denton County Case Detail, the Whites’ Motion to Reconsider 7 the summary judgment was denied, and the moving party failed to appear. The same entry appears on the Judicial Docket Entry for that date. 12 25, 2025 hearing. Appellee then set a bench conference for May 14, 2025, in person, at 8:30 a.m. On May 14, 2025, the trial court signed the Order Granting Plaintiff’s Motion for Summary Judgment. According to the Order, the trial court had considered the motion on the submission date—December 13, 2024. The court further stated that it had considered “the summary judgment evidence, including affidavits, discovery, documentary evidence and Non-Movant’s [singular] pleadings, and the argument[s] of counsel” in deciding the motion. Appellate courts presume that the trial court did not consider untimely filed responses unless the record affirmatively indicates that it did. B.C. v. Steak N Shake Operations, Inc., 598 S.W.3d 256, 259 (Tex. 2020); Johnson v. Parkway Lakes Vill. Homeowners Ass’n, Inc., No. 01-23-00220-CV, 2025 WL 920099, at *2 (Tex. App.— Houston [1st Dist.] Mar. 27, 2025, pet. denied) (mem. op.). Likewise, when the record does not affirmatively indicate the trial court considered an untimely filed summary judgment response, appellate courts do not consider the response or any attached evidence in its review of the summary judgment. Benchmark Bank v. Crowder, 919 S.W.2d 657, 663 (Tex. 1996); Johnson, 2025 WL 920099, at *2. In this case, the record does not affirmatively indicate that the trial court permitted the Whites to file any summary judgment response or evidence late or that it considered any late filed response or evidence. We will consider the Whites’ second response to be filed by Ms. White, as indicated above. That will put her in the same 13 position as Mr. White, and any harm from the court’s erroneous striking of her from the second response will depend on whether the court erred in granting Appellee’s summary judgment. We sustain the Whites’ first issue as to Ms. White regarding the striking of her joinder in the second response. As noted above, whether that was harmful will be determined in the merits discussion. Otherwise, we overrule Issue 1. Regarding the first summary judgment submission, there was no error preserved and no harm demonstrated. Regarding the December 13, 2024 submission, as set out above, the Whites received timely notice of the filing of the Motion for Summary Judgment and the submission date under the Texas Rules of Civil Procedure.8 The Whites timely filed their second response before the December 13, 2024 submission. Therefore, they received due process. See Martin, 989 S.W.3d at 359; Thompson v. Yellowhouse Mach. Co., No. 02-24-00257-CV, 2025 WL 2087930, at *1, n.2 (Tex. App.—Fort Worth July 24, 2025, no pet.) (mem. op.). 8 Additionally, a nonmovant who complains of inadequate notice of a summary judgment submission but admits to knowing of the submission date before it occurs waives its defense of insufficient notice if he fails to bring the defect to the trial court’s attention at or before the erroneously scheduled submission date. Schied v. Merritt, No. 01-15-00466-CV, 2016 WL 3751619, at *4 (Tex. App.—Houston [1st Dist.] July 12, 2016, no pet.) (mem. op.). The record here demonstrates that the Whites received notice of the motion for summary judgment filing and the submission date in a timely fashion and that they timely filed a response, but it does not reflect any objection to the inadequacy of notice by the Whites. Therefore, any complaints as to the adequacy of notice are waived. See id. 14 B. Issue Two The Whites complain that the trial court violated due process by canceling the reconsideration hearing before its noticed date for “failure to appear” and refusing to hear a new trial motion. The crux of the argument that the court canceled the Motion to Reconsider is a note on a proposed order for the Motion. The undated note, in red ink print, says that “Movant failed to appear. [D]j[.]” In the upper right-hand corner, in red ink, is the district clerk’s file stamp notation dated June 17, 2025, 9:32 a.m. If one conflates these two entries, one could argue as the Whites do. That inference, though, is not reasonable. Although both entries are in red ink, they obviously use different font. They are separated by half a page laterally, and these are signed or initialed by two different people. “[D]j” corresponds to the presiding judge’s initials while the other entry is by a deputy clerk. The reasonable inference is that “dj”’s entry was made at a different time after the Whites failed to appear, as noted on the judicial docket sheet. The Whites also complain that they were denied due process because the trial court did not have a hearing on their Motion for New Trial. Their Motion for New Trial was filed on May 19, 2025. There is nothing in the record showing that the Whites requested a hearing on their motion. Ordinarily, a trial court is not required to conduct a hearing on a motion for new trial or to even sign an order on a motion for new trial unless the motion requires presentation of evidence. Slack v. Shreve, No. 12-24-00014-CV, 2024 WL 4644610, at *9 (Tex. App.—Tyler Oct. 31, 2024, no pet.) (mem. op.). If a hearing is necessary, a party must request a hearing from the court; 15 failure to request a hearing constitutes waiver of any error from the failure to conduct a hearing. Mitchell v. Mitchell, No. 07-26-00058-CV, 2026 WL 1408803, at *3 n.3 (Tex. App.—Amarillo May 19, 2026, no pet. h.) (mem. op.). The Whites’ motion dealt in part with issues that would require a hearing, including newly discovered evidence. Slack, 2024 WL 4644610, at *9. Having failed to request a hearing on the motion, their complaint is waived. Mitchell, 2026 WL 1408803, at *3 n.3. Issue Two is overruled. C. Issue Three The Whites contend that “the judgment is void because the court: (a) first inserted the new dispositive finding ‘Defendants have not pled any affirmative defense’ in the final order, and (b) failed to serve the order, effectively concealing the finding. (CR 893–895).” First, the Whites are using an incomplete quote from the final order. In full context, the order states, “The Court finds that Defendants have not pled any affirmative defense that would preclude summary judgment in this case.” [Emphasis added.] It is a significant difference. Whether Defendants had pled any affirmative defense is a fact question—one that is clearly answered in their favor as they had pled what they characterized as affirmative defenses. The actual statement in the final order is that the Defendants had not pled any affirmative defense “that would preclude summary judgment in this case.” That statement is a conclusion of law. Second, as noted above, the trial court had plenary power to modify any previous interlocutory ruling, and when it did, it notified the parties. 16 There was nothing surreptitious either. The Order Granting Plaintiff’s Motion for Summary Judgment was signed on May 14, 2025, and file stamped by the district clerk that same day. Parties are charged with notice of all orders in the case to which they are a party. Weirich v. Weirich, 833 S.W.2d 942, 946 (Tex. 1992); Chavez v. Tex. Tech Healthcare Sys., No. 11-08-00321-CV, 2010 WL 3008807, at *2 (Tex. App.—Eastland July 29, 2010, no pet.) (mem. op.). Finally, the Whites admitted that on May 14, 2025, they received an email from the court coordinator that the “MSJ order has been signed and filed with the Clerk’s office.” As the Whites admitted, when they eventually sought a copy from the clerk’s office, they received it. Issue Three is overruled. D. Issues Five through Nine Issues Five through Nine are characterized by the Whites as “merits-related.” However, their arguments consist of sporadic case citations, 9 general statements of law, 9 Appellants cite cases that do not support their arguments. For example, they cite Gaines v. Kelly, 235 S.W.3d 179, 182–83 (Tex. 2007), to argue that “[a] void instrument cannot be revived by recordation or assignment” and that “recording a void instrument conveys no rights and provides no constructive notice.” But Gaines does not discuss void instruments or the effect of recording them. Appellants likewise cite AIC Management v. Crews, 246 S.W.3d 640, 645 (Tex. 2008), and Browning v. Prostok, 165 S.W.3d 336, 346 (Tex. 2005), for propositions not supported by those cases. In other parts of the brief, the Whites cite cases for general statements of law that they stretch to support their issues, but the cases do not support the Whites’ ultimate arguments. For example, they cite Hammonds v. Holmes, 559 S.W.2d 345, 347 (Tex. 1977), and Bonilla v. Roberson, 918 S.W.2d 17, 22 (Tex. App.—Corpus Christi 1996, no writ), to argue that a deed-of-trust trustee’s lack of neutrality “voids every act done under that compromised authority,” and thus the foreclosure deed was void because the trustee who executed it also acted as counsel for Fifth Third Bank. But these cases say nothing 17 and conclusory arguments without meaningful analysis. As we summarized above, this does not satisfy Texas Rule of Appellate Procedure 38.1 and constitutes waiver because of inadequate briefing. See In re J.D., 2025 WL 2810523, at *2; see also Britton v. Almasri, No. 02-25-00298-CV, 2025 WL 3119024, at *7 (Tex. App.—Fort Worth Nov. 6, 2025, no pet.) (mem. op.); Gunderson v. Nat’l Indoor RV Ctrs., LLC, No. 02-24-00025-CV, 2024 WL 3365233, at *2–4 (Tex. App.—Fort Worth July 11, 2024, pet. denied) (mem. op.). Issues Five through Nine are overruled. 10 IV. Conclusion Having overruled all of Mr. Whites’ issues, we affirm the judgment of the trial court as to him. Having overruled all of Ms. Whites’ issues except Issue One as to the striking of her response but overruling her remaining issues, we hold that there was no about voiding actions in such a circumstance. Cf. Valley v. Patterson, 614 S.W.2d 867, 872 (Tex. App.—Corpus Christi 1981, no writ) (“Mere interest in the secured debt does not disqualify one from acting as a trustee.”). Appellants also cite Sharp v. Kowalski, 767 S.W.2d 662, 664 (Tex. 1989), and Myers v. Crews, 847 S.W.2d 271, 275 (Tex. App.— Texarkana 1992, no writ), but we were unable to locate those cases at those citations or by searching for cases with those styles. 10 Moreover, the Whites did not carry their summary judgment burden to overcome the presumption of validity of the substitute trustee’s deed’s recitals, see Houston First Am. Savings & Musick, 650 S.W.2d 764, 767–68 (Tex. 1983). None of their self-serving documents filed in response to the motion for summary judgment raise any genuine issue of material fact concerning the underlying foreclosure sale or the substitute trustee’s deed. Nor did the Whites file any counterclaim to set aside the sale and cancel the trustee’s deed. See Bonilla, 918 S.W.2d at 22. Thus, to the extent they did not waive their merits-based appellate issues, we overrule Issues Five through Nine because the Whites failed to carry their summary judgment burden. 18 reversible error in the trial court’s judgment as to Ms. White. The judgment of the trial court is affirmed. /s/ Mike Wallach Mike Wallach Justice Delivered: August 27, 2026 19