Texas Appellate Court Rejects Pro Se Challenges to Title IV-D Child Support and Judicial Conflicts of Interest

Memorandum Opinion by Justice Cron, 13-24-00087-CV, January 26, 2026.

On appeal from the 353rd District Court of Travis County, Texas

Synopsis

The Thirteenth Court of Appeals affirmed a final SAPCR order, holding that the appellant waived his constitutional and systemic challenges to the Title IV-D child support framework. By failing to provide substantive legal analysis or relevant authority as required by Texas Rule of Appellate Procedure 38.1(i), the appellant’s arguments regarding judicial conflicts of interest and due process were forfeited.

Relevance to Family Law

For the family law practitioner, this case serves as a critical reminder of the “briefing waiver” doctrine, particularly when dealing with pro se litigants or fringe constitutional arguments. It reaffirms that even when a party alleges fundamental due process violations or challenges the state’s authority to mandate child support under Title IV-D, the appellate courts will not perform the litigant’s research or craft their arguments. The opinion underscores that the Title IV-D program’s administrative structure does not, in itself, create a per se conflict of interest for trial judges, and any such claim must be supported by rigorous legal scaffolding to survive appellate review.

Case Summary

Fact Summary

This appeal arose from a Suit Affecting the Parent-Child Relationship (SAPCR) initiated by the Father, who proceeded pro se through significant portions of the litigation. Following a jury trial and subsequent post-trial hearings, the trial court entered an “Agreed Final Order” (notwithstanding Father’s ultimate opposition to specific terms) naming the parents joint managing conservators and ordering the Father to pay guideline child support. Throughout the proceedings, the Father filed several unorthodox documents, including an “Affidavit of Truth” claiming “Sovereign” status and a “Petition to Terminate Withholding,” arguing that he could not be forced into the Title IV-D program without his consent. He further alleged that federal incentive payments to the state created a financial conflict of interest for the judiciary.

Issues Decided

The Court of Appeals addressed whether the trial court erred by:

1. Ordering child support within the Title IV-D framework without the obligor’s consent.
2. Presiding over the case despite alleged conflicts of interest stemming from Title IV-D incentive payments.
3. Violating the Due Process Clause of the Fourteenth Amendment via its relationship with the Title IV-D agency.
4. Overriding the Father’s right to equal possession and access.

Rules Applied

The court’s decision centered on Texas Rule of Appellate Procedure 38.1(i), which mandates that an appellant’s brief contain a clear and concise argument supported by appropriate citations to authorities and the record. Under Mansfield State Bank v. Cohn, pro se litigants are held to the same standards as licensed attorneys regarding procedural compliance. The court also referenced Borusan Mannesmann Pipe US, Inc. v. Hunting Energy Serv. to emphasize that even constitutional issues can be forfeited or waived if the briefing is inadequate.

Application

The court’s application of the law was a study in appellate discipline. Justice Cron noted that while the Father grouped his first three issues together, the authorities he cited—Blessing v. Freestone, Holmberg v. Holmberg, and Wehunt v. Ledbetter—were fundamentally inapplicable. Blessing specifically holds that Title IV-D does not create an individual federal right to force state compliance, rather than prohibiting child support orders. Furthermore, the Father failed to provide any substantive analysis connecting these federal cases to his theory that the Texas judiciary suffers from a systemic conflict of interest. Because the Father offered no roadmap for how the trial court’s actions violated specific constitutional or statutory provisions—other than general assertions of sovereignty and bias—the court declined to perform the legal research on his behalf. The court treated the Father’s “sovereign citizen” rhetoric as a failure to engage with the actual legal standards governing SAPCR orders in Texas.

Holding

The Court of Appeals affirmed the trial court’s judgment in its entirety.

The court held that the Father waived his challenges to the Title IV-D program and judicial impartiality because his brief lacked the substantive analysis required by Rule 38.1(i). The court reaffirmed that simply citing cases is insufficient; the appellant must explain how the cited law applies to the facts of the case to avoid forfeiture.

The court further held that the Father’s fourth issue regarding equal possession was waived for similar reasons. Despite the Father’s claim that the trial court ignored “Supreme Court law,” he failed to provide the necessary legal analysis to overcome the broad discretion typically afforded to trial courts in determining the best interest of the child and possession schedules.

Practical Application

This opinion provides a strategic roadmap for trial counsel facing “sovereign citizen” or “anti-IV-D” arguments. When a counter-party makes broad, sweeping claims about the unconstitutionality of child support or judicial bias based on federal funding, the most effective response at the appellate level is often to highlight the lack of substantive, relevant authority. Litigators should rely on the strict pro se standard established in Mansfield State Bank to ensure that meritless constitutional challenges are dismissed on procedural grounds before the court even reaches the (often non-existent) merits of the argument.

Checklists

Defending Against Inadequate Briefing (TRAP 38.1)

• Identify Conclusory Statements: Flag issues where the appellant makes assertions without explaining the “why” or “how.”
• Analyze Citations: Determine if the cited authorities actually support the proposition or if they are “red herrings” (e.g., citing Blessing for a conflict-of-interest claim).
• Check the Record: Ensure the appellant has provided specific record citations; if they are missing, move for waiver.

Argue Forfeiture Early: In the Appellee’s Brief, lead with the argument that the appellant has failed to meet their burden under Rule 38.1(i).

Addressing Title IV-D / Sovereign Challenges

• Establish Consent is Irrelevant: Point to the Texas Family Code’s mandatory child support provisions, which operate independently of an obligor’s “consent” to the IV-D system.
• Request Findings of Fact: If a litigant alleges judicial bias, ensure the record reflects the court’s neutral application of the “Best Interest of the Child” standard to insulate the order from due process challenges.

Citation

In the Interest of P.J.G., a Child, No. 13-24-00087-CV (Tex. App.—Corpus Christi–Edinburg Jan. 26, 2026, no pet. h.) (mem. op.).

Full Opinion

View the Full Opinion Here

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