Full Opinion

In the Court of Appeals Second Appellate District of Texas at Fort Worth ___________________________ No. 02-26-00304-CV ___________________________ CAROLINE HAYLES BROOKS, Appellant V. AUDLEY W. BROOKS, Appellee On Appeal from the 360th District Court Tarrant County, Texas Trial Court No. 360-752702-24 Before Kerr, Womack, and Wallach, JJ. Memorandum Opinion by Justice Kerr MEMORANDUM OPINION Appellant Caroline Hayles Brooks (Wife) files this pro se appeal from an agreed final divorce decree based upon the terms of a mediated settlement agreement (MSA). In what amounts to a single issue,1 Wife attempts to argue that the trial court abused its discretion by signing a final divorce decree that materially differs from the MSA. But Wife has forfeited her appellate complaint due to inadequate briefing. Pro se appellants are held to the same standards as licensed attorneys and must comply with the applicable laws and rules of procedure; otherwise, pro se parties “would be given an unfair advantage over [parties] represented by counsel.” Mansfield State Bank v. Cohn, 573 S.W.2d 181, 184–85 (Tex. 1978); see Flores v. Off. Depot, Inc., No. 02-10-00311-CV, 2011 WL 2611140, at *2 (Tex. App.—Fort Worth June 30, 2011, no pet.); see also Smale v. Williams, 590 S.W.3d 633, 639 (Tex. App.—Texarkana 2019, no pet.) (“The law is well settled that ‘[a] party proceeding pro se must comply with all applicable procedural rules’ and is held to the same standards as a licensed attorney.” (quoting Paselk v. Rabun, 293 S.W.3d 600, 611 (Tex. App.—Texarkana 2009, pet. denied))). Thus, all appellants—whether acting pro se or through counsel—must 1 Wife enumerates five issues in her brief, but at their core, they all raise the same complaint—that the trial court abused its discretion by signing a divorce decree that materially differs from the MSA. Accordingly, we treat her issues as a single appellate complaint. See, e.g., Est. of Meyers, No. 02-25-00189-CV, 2025 WL 3723746, at *2 n.3 (Tex. App.—Fort Worth Dec. 23, 2025, no pet.). 2 properly present their appeals in accordance with the Texas Rules of Appellate Procedure. Smale, 590 S.W.3d at 639; Flores, 2011 WL 2611140, at *2. The Texas Rules of Appellate Procedure require an appellant’s brief to contain, among other things, a “clear and concise argument for the contentions made, with appropriate citations to authorities and to the record.” See Tex. R. App. P. 38.1(i). Wife’s brief wholly fails to comply with this requirement. It contains no citations to the record, and while it lists the names of four cases, it does not actually cite any of them or—with one exception—even identify the respective courts that decided them. Nor does it explain how the enumerated cases support Wife’s appellate argument. See Player v. Booker, No. 02-24-00318-CV, 2025 WL 1006282, at *3 (Tex. App.—Fort Worth Apr. 3, 2025, no pet.) (holding that appellant had waived complaint due to inadequate briefing because, inter alia, she had failed to “explain how [her cited] cases—or any other authorities cited in her brief—support[ed] her appellate argument”). Further, Wife’s argument is unclear. She vaguely asserts that “[c]hanges were made to [d]ischarge from discovery[,] [p]roperty division, [d]ebt, NOTICE, [t]axes, [r]elease of ALL [c]laims stated on divorce[,] and other sections,” but she does not identify any specific variances between the MSA and the divorce decree or reference any particular language in either document. She also generally claims that the decree “allocates debts and financial obligations not contained in the MSA” and that the decree contains “interest provisions” that “were never agreed to,” but she fails to 3 specify the particular “debts,” “obligations,” or “interest provisions” that are the subject of her complaint. And, as noted, she failed to include any record citations in her brief that would help us to identify the specific provisions of the decree that she seeks to challenge. We interpret the appellate procedural rules “reasonably, yet liberally, so that the right to appeal is not lost by imposing requirements not absolutely necessary to effect the purpose of a rule.” Verburgt v. Dorner, 959 S.W.2d 615, 616–17 (Tex. 1997); see also Tex. R. App. P. 38.9 (providing that substantial compliance with the briefing rules is sufficient). Nonetheless, it is “absolutely necessary” for a party asserting error on appeal to “acquaint the court with the issues in a case and to present argument that will enable the court to decide the case” by demonstrating how the record and the law support her contentions. Tex. R. App. P. 38.9; Verburgt, 959 S.W.2d at 616–17; see San Saba Energy, L.P. v. Crawford, 171 S.W.3d 323, 338 (Tex. App.—Houston [14th Dist.] 2005, no pet.) (recognizing that “parties asserting error on appeal still must put forth some specific argument and analysis showing that the record and the law supports their contentions”). When, as here, an appellant fails to make a clear argument and provides no record references, no legal analysis, and no citations to relevant legal authorities, nothing is presented for our review. See Sister Initiative, LLC v. Broughton Maint. Ass’n, No. 02-19-00102-CV, 2020 WL 726785, at *25 (Tex. App.—Fort Worth Feb. 13, 2020, pet. denied) (“An appellant’s failure to cite legal authority to or provide substantive analysis of a legal issue presented results in waiver of the appellant’s 4 complaint.”); AMX Enters., L.L.P. v. Master Realty Corp., 283 S.W.3d 506, 525 (Tex. App.—Fort Worth 2009, no pet.) (op. on reh’g) (“An issue unsupported by citation to any legal authority presents nothing for the court to review.”); Karen Corp. v. Burlington N. & Santa Fe Ry. Co., 107 S.W.3d 118, 125 (Tex. App.—Fort Worth 2003, pet. denied) (“For this court to rule on an issue on appeal, the party who brings the point forward must support it by argument and authorities.”); see also San Saba Energy, 171 S.W.3d at 338 (holding that “[e]ven under a liberal construction” of the briefing requirements appellant had inadequately briefed its issue because it had “cite[d] no part of the record and [had] ma[d]e no specific [legal] argument”). We cannot speculate as to the specific legal bases for Wife’s challenges to the trial court’s divorce decree, nor can we “redraft and articulate for [Wife] what we think [she] meant to raise on appeal.” Strange v. Cont’l Cas. Co., 126 S.W.3d 676, 678 (Tex. App.—Dallas 2004, pet. denied) (holding the appellant’s inadequate briefing failed to preserve any issues for review where the brief contained no argument, no record references, and no citations to legal authority). Thus, we conclude that Wife has forfeited her sole appellate issue, and we affirm the trial court’s divorce decree.2 See Tex. R. App. P. 38.1, 38.9. Because our review of the divorce decree has revealed no material variances 2 from the MSA, Wife’s appellate complaint would fail on the merits even if it had not been forfeited. See In re T.L.T., No. 05-16-01367-CV, 2018 WL 1407098, at *3 (Tex. App.—Dallas Mar. 21, 2018, no pet.) (“Parties to a[n] MSA need not agree to all of the provisions to be contained in the divorce decree. They are required only to reach an agreement as to all material terms.” (citation modified)). As noted, Wife asserts that 5 /s/Elizabeth Kerr Elizabeth Kerr Justice Delivered: September 24, 2026 the decree “allocates debts and financial obligations not contained in the MSA.” But the only debt allocated to Wife in the decree that is not specifically enumerated in the MSA is a $77,500 debt to be paid to Husband within 180 days of the decree’s entry, and although the MSA does not list this as a “debt” allocated to Wife, it explicitly obligates Wife to pay this amount to Husband within the 180-day timeframe set forth in the decree. Further, to the extent that Wife complains about the decree’s language providing that the $77,500 debt “shall bear interest at [five] percent per year” if it is not timely paid, such language merely effectuates the parties’ agreement; it does not materially alter it. See Glynn v. Glynn, 651 S.W.3d 348, 354–55 (Tex. App.—Houston [1st Dist.] 2022, no pet.) (“If the decree adopts mechanisms to enforce the parties’ agreement while remaining consistent with their intent, it is enforceable.” (citing Davis v. Davis, No. 01-12-00701-CV, 2014 WL 890899, at *9 (Tex. App.—Houston [1st Dist.] Mar. 6, 2014, no pet.))); see also Davis, 2014 WL 890899, at *9 (clarifying that the “proper inquiry” when evaluating whether a trial court has failed to enforce an MSA “is not a mechanical examination of whether the divorce decree varies from the terms of the MSA”; rather it is “whether variances by the trial court significantly alter the parties’ written agreement in a way that deviates from the parties’ intent as manifested in that agreement”). 6