Peterson v. Office of the AG, 990 S.W.2d 830, 833 (Tex. App.-Fort Worth 1999, no pet.); Lueg v. Lueg, 976 S.W.2d 308, 313 (Tex. App.-Texarkana 1998, pet. denied); see S.L. v. S.L., No. 02-19-00017-CV, 2020 Tex.App. LEXIS 6002, at *12 (Tex. App.-Fort Worth July 30, 2020, no pet.) (mem. op.) (acknowledging that "as between the sole managing conservator and the possessory conservator, the Family Code gives only the sole managing conservator the express right to receive child support . . .")

Thus, the designation, standing alone, provides no insight into the nature of the relationship. See Lueg v. Lueg, 976 S.W.2d 308, 311 (Tex.App.-Corpus Christi 1998, pet. denied) (concluding recusal not required where one party's attorney was judge's past campaign manager; that designation alone provided no insight into the nature of the relationship). Further context is required.

Mother relies on a case in which the trial court abused its discretion by ordering a sole managing conservator to pay child support to a possessory conservator. Lueg v. Lueg, 976 S.W.2d 308, 313 (Tex. App.—Corpus Christi-Edinburg 1998, pet. denied). Despite some similarities in the division of parental rights and duties, that case is inapposite because Mother and Father are joint managing conservators.

TEX. R. CIV. P. 18a(j)(1)(A); Lueg v. Lueg, 976 S.W.2d 308, 310 (Tex. App.—Corpus Christi 1998, pet. denied). An abuse of discretion occurs when a trial court's ruling is arbitrary and unreasonable, without regard for guiding legal principles, or without supporting evidence.

We review the denial of a motion to recuse under an abuse of discretion standard on appeal from the final judgment. Lueg v. Lueg, 976 S.W.2d 308, 310 (Tex. App.—Corpus Christi 1998, pet. denied); see TEX. R. CIV. P. 18a(j)(1)(A).

We review the denial of a motion to recuse under an abuse of discretion standard on appeal from the final judgment. Lueg v. Lueg, 976 S.W.2d 308, 310 (Tex. App.—Corpus Christi 1998, pet. denied); see TEX. R. CIV. P. 18a(j)(1)(A).

A party who fails to support his or her contentions with authority or citations to the record when appropriate forfeits the issue due to inadequate briefing. See Morrill v. Cisek, 226 S.W.3d 545, 548-49 (Tex. App.—Houston [1st Dist.] 2006, no pet.) (holding party waived issues by failing to cite to record and authority); Lueg v. Lueg, 976 S.W.2d 308, 310 (Tex. App.—Corpus Christi 1998, pet. denied) (same). We are not required to sort through the record to find facts to support appellant's position. Otherwise, our independent review of the record would transform the court from a neutral adjudicator to an advocate.

Trisha's statements during the June 1, 2012 hearing constituted an express waiver of a jury trial. See Lueg v. Lueg, 976 S.W.2d 308, 311-12 (Tex. App.—Corpus Christi 1998, pet. denied). During that same hearing, Jack's counsel confirmed on the record that Jack was not seeking a jury trial because he was not requesting any relief that would involve a jury issue.

A party who fails to support his or her contentions with authority or citations to the record when appropriate waives the issue due to inadequate briefing. See Morrill v. Cisek, 226 S.W.3d 545, 548-49 (Tex. App.—Houston [1st Dist.] 2006, no pet.) (holding party waived issues by failing to cite to record and authority); Lueg v. Lueg, 976 S.W.2d 308, 310 (Tex. App.—Corpus Christi 1998, pet. denied) (same). We are not required to sort through the record to find facts to support appellant's position. Otherwise, our independent review of the record would transform the court from a neutral adjudicator to an advocate.

Rule 38 requires that the Bank provide such discussion of the facts and authorities as may be necessary to maintain its argument in support of its limitations issue. See Lueg v. Lueg, 976 S.W.2d 308, 312 (Tex. App.—Corpus Christi 1998, pet. denied) (holding that an argument was waived because the "brief cites us to no specific record references for these alleged facts on record"); see also Flores v. United Freedom Assocs., 314 S.W.3d 113, 116 (Tex. App.—El Paso 2010, no pet.) (overruling an argument as inadequately briefed because appellant failed to cite legal authorities or present argument); cf. Weeks Marine, Inc. v. Garza, 371 S.W.3d 157, 162 (Tex. 2012) ("An appellant can preserve error 'in the body of their appellate brief,' even if it is not separately listed in the notice of appeal or presented as an issue in the brief."). As our sister court explained: