Opinion
No. 04-04-00404-CV
Delivered and Filed: February 2, 2005.
Appeal from the 37th Judicial District Court, Bexar County, Texas, Trial Court No. 2003-CI-14360, Honorable Pat Boone, Judge Presiding.
Affirmed.
Sitting: Catherine STONE, Justice, Karen ANGELINI, Justice, Sandee Bryan MARION, Justice.
MEMORANDUM OPINION
Frank and Helen Herrera, acting pro se, appeal the summary judgment granted in favor of Bombardier Capital Inc. Bombardier sued the Herreras for possession of the manufactured home they occupied. In two issues, the Herreras contend generally that the trial court erred by granting summary judgment to Bombardier. We affirm the trial court's judgment.
"A pro se litigant is held to the same standards as licensed attorneys and must comply with applicable laws and rules of procedure." Shull v. United Parcel Serv., 4 S.W.3d 46, 52-53 (Tex.App.-San Antonio 1999, pet. denied) (citing Holt v. F.F. Enters., 990 S.W.2d 756, 759 (Tex.App.-Amarillo 1998, pet. denied)). While it is true that pro se pleadings and briefs are to be liberally construed, this does not mean that a pro se litigant is not required to comply with applicable rules. Id. at 53. To do otherwise would be to give a pro se litigant an unfair advantage over a litigant who is represented by counsel. Id.
The Texas Rules of Appellate Procedure require an appellant's brief to contain "a clear and concise argument for the contentions made, with appropriate citations to authorities and to the record." Tex.R.App.P. 38.1(h). Issues on appeal unsupported by argument or citation to any legal authority present nothing for the appellate court to review. Birnbaum v. Law Offices of G. David Westfall, P.C., 120 S.W.3d 470, 477 (Tex.App.-Dallas 2003, pet. denied). "[W]e cannot speculate as to the substance of the specific issues appellant claims we must address." Strange v. Cont'l Cas. Co., 126 S.W.3d 676, 678 (Tex.App.-Dallas 2004, pet. denied). We simply have "no duty to perform an independent review of the record and applicable law to determine whether the error complained of occurred." Id.
In this case, we are faced with a difficult task in addressing the appeal of these pro se appellants. The Herreras' brief provides us with nothing more than a list of two "Points of Error." The Herreras provide no discussion or argument as to any point, and they cite neither the record nor any legal authority anywhere in their brief.
We have little latitude on appeal; we cannot remedy deficiencies in a litigant's brief. This court "cannot redraft and articulate for appellant[s] what we think [they] meant to raise on appeal." Id. Adequate briefing is minimally required for us to review the proceedings below. Because the Herreras have inadequately briefed their two appellate issues, nothing is presented for our review. See Birnbaum, 120 S.W.3d at 477.
The judgment of the trial court is affirmed.