John Kevin Gardner v. Julia Gardner, 12-14-00139-CV

John Kevin Gardner and Julia Elaine Gardner married in December 2011; Julia filed for divorce in December 2013 and indicated the parties would reach an agreement dividing community property.
John filed a counterpetition and sought reimbursement from the community estate for funds he claimed benefited Julia’s separate estate.
The parties executed an agreed final decree of divorce; John, appearing pro se, signed and approved its form and substance; the trial court signed the agreed decree awarding certain property as separate to each party.
John appealed pro se, raising eight issues: lack of a timely trial date/hearing, lack of notice, alleged nullification of the agreement, Julia’s failure to return property or produce documents, claim for reimbursement, and claims based on Julia’s alleged adultery.
The Court of Appeals reviewed the briefing and the record and concluded John’s appellate briefing was conclusory and lacked record citations or legal analysis; additionally, he failed to preserve the complaints at trial.
The court affirmed the trial court’s agreed final decree and assessed appellate costs against John.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Trial scheduling/hearing & notice	Lack of timely trial date, no hearing, no notice; decree unenforceable	Decree was agreed and signed by both parties; local rule allows signing without hearing if no objection	Overruled — waived by insufficient briefing and not preserved at trial; local rule supports signing without hearing
Validity of agreement before filing	Agreement was "null and void" before Julia filed decree	Agreement was executed and approved by John when he signed decree	Overruled — no preserved complaint and inadequate appellate briefing
Failure to return property/produce documents	Julia failed to return John’s property and failed to comply with discovery	Issues not raised in trial court before decree; no record preservation	Overruled — not preserved and inadequately briefed
Reimbursement & adultery claims	Seeks reimbursement for remodeling and claims community estate due to adultery	Claims were not presented to trial court prior to signing decree; no supporting record or legal analysis	Overruled — claims not preserved and waived by inadequate briefing

Huey v. Huey, 200 S.W.3d 851 (Tex. App.—Dallas 2006) (appellate court not required to brief issues for appellant)
WorldPeace v. Comm’n for Lawyer Discipline, 183 S.W.3d 451 (Tex. App.—Houston [14th Dist.] 2005) (failure to provide argument or record citations waives issue)
Med. Specialist Group, P.A. v. Radiology Assocs., L.L.P., 171 S.W.3d 727 (Tex. App.—Corpus Christi 2005) (same)
Fredonia State Bank v. Gen. Am. Life Ins. Co., 881 S.W.2d 279 (Tex. 1994) (appellate court may deem issues waived for inadequate briefing)
Bolling v. Farmers Branch Ind. Sch. Dist., 315 S.W.3d 893 (Tex. App.—Dallas 2010) (general legal statements are insufficient briefing)
San Saba Energy, L.P. v. Crawford, 171 S.W.3d 323 (Tex. App.—Houston [14th Dist.] 2005) (appellate briefing must show record and law support)
Valadez v. Avitia, 238 S.W.3d 843 (Tex. App.—El Paso 2007) (appellate court will not independently review record to find error)
Sweed v. City of El Paso, 195 S.W.3d 784 (Tex. App.—El Paso 2006) (brief conclusory statements do not satisfy briefing rules)