Lehmann v. Har-Con Corp., 39 S.W.3d 191, 205 (Tex. 2001); see also In re H.C.C., No. 01-16-00876-CV, 2017 WL 6520228, at *5 (Tex. App.-Houston [1st Dist.] Dec. 21, 2017, no pet.) (mem. op.). "If there is any doubt as to the judgment's finality," we should review the record to determine whether the trial court intended the judgment to be final.

In deciding whether a material and substantial change of circumstances has occurred, a fact finder is not confined to rigid or definite guidelines; instead, the determination is fact specific and must be made according to the circumstances as they arise. See In re H.C.C., No. 01-16-00876-CV, 2017 WL 6520228, at *9 (Tex. App.—Houston [1st Dist.] Dec. 21, 2017, no pet.) (mem. op.); Arredondo v. Betancourt, 383 S.W.3d 730, 734-35 (Tex. App.—Houston [14th Dist.] 2012, no pet.). To demonstrate that a material and substantial change of circumstances has occurred, the evidence must show the conditions that existed at the time of the entry of the prior order as compared to the circumstances existing at the time of the trial on the petition to modify.

Injunctions prohibiting use of corporal punishment, among other limitations, are often included in SAPCR orders. See In Interest of H.C.C., No. 01-16-00876-CV, 2017 WL 6520228, at *6 (Tex. App.—Houston [1st Dist.] Dec. 21, 2017, no pet.) (mem. op.). The permanent mutual injunction is reasonably specific and unambiguous, expressly enjoining both Runnels and Craddock-Neal from "[u]sing corporal punishment on any minor child the subject of this suit at any time[.]"

See TEX. CONST. art. I, § 15; TEX. R. CIV. P. 216; In re H.C.C., No. 01-16-00876-CV, 2017 WL 6520228, at *4 (Tex. App.—Houston [1st Dist.] Dec. 21, 2017, no pet.) (mem. op.) (holding that trial court did not abuse its discretion by denying request for a jury trial that was filed 16 days before the trial setting). The mother filed a jury demand and paid the fee on October 1, 2018, which was 29 days before the date set for trial of the case on the nonjury docket.