L.H. v. N.H., 02-15-00116-CV

Lacy and Neil married in 2010, separated in 2013, and disputed conservatorship of their two children during divorce proceedings; Neil sought a social study and requested primary managing conservatorship.
The trial court ordered a social study by Rosemary Rodriguez, who recommended Neil be named primary managing conservator, in part based on recorded telephone calls and social-media materials.
At the final hearing Lacy appeared pro se, was denied a continuance, cross-examined Rodriguez, and challenged the report only for inaccuracies (not for alleged illegality of the recordings).
The trial court admitted the social study, stated it gave the study significant weight, awarded Neil the exclusive right to establish the children’s residence, ordered child support from Lacy, and adopted Neil’s property-division proposal.
Lacy later (with counsel) raised for the first time in a motion for new trial that parts of the social study relied on recordings she claims were illegally obtained and that the social study failed to meet Family Code requirements.
The trial court did not expressly rule on the motion for new trial (overruled by operation of law); Lacy appealed, arguing (1) improper admission/consideration of the social study and (2) that the court abused its discretion by limiting her presentation of evidence.

Issue	Plaintiff's Argument (Lacy)	Defendant's Argument (Neil)	Held
Admissibility/use of social study	Social study relied on illegally obtained phone recordings and noncompliant family-code procedures, so it was inadmissible and should not have been considered	Study was properly admitted; Lacy failed to timely and specifically object at trial to preserve these grounds	Overruled — error waived for appeal because Lacy’s trial objection only raised inaccuracies, not the later legal arguments (preservation rule applies)
Limitation on presentation of evidence	Trial court curtailed Lacy’s questioning and testimony, denied continuance and closing argument, and thus abused discretion and deprived her fair presentation	Court managed testimony to prevent waste of time and improper testimony; afforded Lacy latitude and opportunities to present evidence; pro se litigant must follow procedural rules	Overruled — no abuse of discretion; court reasonably controlled examination, gave leeway, and could limit testimony to avoid wasting time

Bushell v. Dean, 803 S.W.2d 711 (Tex. 1991) (contemporaneous-objection rule for preserving error)
Transcon. Realty Inv’rs, Inc. v. Wicks, 442 S.W.3d 676 (Tex. App.—Dallas 2014) (preservation and waiver principles)
Tryco Enters., Inc. v. Robinson, 390 S.W.3d 497 (Tex. App.—Houston [1st Dist.] 2012) (preservation of evidentiary objections)
In re M.A.S., 233 S.W.3d 915 (Tex. App.—Dallas 2007) (trial-court control over witness examination; abuse-of-discretion review)
Dow Chem. Co. v. Francis, 46 S.W.3d 237 (Tex. 2001) (trial court may intervene to expedite trial and prevent waste of time)