in the Interest of A.J.L. and V.C.L., Children, 14-16-00834-CV

Parents divorced in 2010; a 2013 mediated settlement agreement (MSA) was incorporated into a 2013 order naming them joint managing conservators and providing no child support.
Mother sued in 2014 to modify the 2013 order seeking sole or primary-residence conservatorship, exclusive decision-making, child support, restrictions on Father’s alcohol use during possession, and modified possession.
Father filed a hybrid no-evidence and traditional summary judgment motion in 2016; the trial court granted only the no-evidence portion and then Father nonsuited his counterpetition, rendering the no-evidence order final and appealable.
Father’s no-evidence motion challenged (a) lack of evidence of a material and substantial change in circumstances (statutory elements) and (b) that modification would be in the children’s best interest.
Mother opposed with voluminous attachments (114 pages) but her response only generally incorporated exhibits by reference and did not point to specific evidence or argument identifying which evidence raised fact issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Legal sufficiency of Father’s no-evidence motion under Tex. R. Civ. P. 166a(i)	Mother: motion is defective—cites non-existent code section, wrong time frame, fails to specify which requested best‑interest changes are challenged, and fails to identify which child.	Father: motion identified the statutory elements and incorporated the statutory text; typographical or framing imprecision does not defeat notice required by Rule 166a(i).	Court: Overruled Mother; motion was legally sufficient despite minor citation/typographical issues because it adequately informed Mother of the challenged elements.
Whether Mother produced evidence raising a genuine issue of material fact on material & substantial change since the MSA/2013 order	Mother: attached affidavits, discovery responses, pleadings and documents (incorporated) create genuine fact issues as to changed circumstances.	Father: Mother failed to point to or cite specific evidence; general incorporation of voluminous records is insufficient to defeat a no-evidence motion.	Court: Held trial court did not err; Mother failed to identify specific evidence raising a fact issue, so no-evidence summary judgment properly granted.

Timpte Indus., Inc. v. Gish, 286 S.W.3d 306 (Tex. 2009) (Rule 166a(i) requires specificity in no‑evidence motions to inform nonmovant and define issues)
Sudan v. Sudan, 199 S.W.3d 291 (Tex. 2006) (no‑evidence summary judgment standards)
First United Pentecostal Church of Beaumont v. Parker, 514 S.W.3d 214 (Tex. 2017) (standard for what constitutes a genuine issue of material fact)
Jose Fuentes Co., Inc. v. Alfaro, 418 S.W.3d 280 (Tex. App.—Dallas 2013) (no‑evidence motions should challenge elements, not mere factual theories)
Cincinnati Life Ins. Co. v. Cates, 927 S.W.2d 623 (Tex. 1996) (principle that appellate courts consider only the grounds expressly granted by the trial court)