Betsy L. Reeves vs. Elisabeth M. Sobczak

BETSY L. REEVES, ) ) Respondent, ) ) WD87729 v. ) OPINION FILED: ) DECEMBER 2, 2025 ELISABETH M. SOBCZAK, ) ) Appellant. )

Appeal from the Circuit Court of Boone County, Missouri The Honorable Sue M. Crane, Judge

Before Division Four: Anthony Rex Gabbert, Chief Judge, Presiding, Lisa White Hardwick, Judge, and Karen King Mitchell, Judge

Elisabeth Sobczak appeals the Boone County Circuit Court's grant of a motion to enforce a dissolution judgment and the award of attorneys' fees to Reeves. She presents seven points on appeal. The appeal is dismissed. Facts In May 2022, Betsy Reeves filed a petition for dissolution of her marriage with Sobczak. In February 2024, the court entered judgment dissolving the marriage and approving the settlement agreement. The judgment and decree of dissolution of marriage stated in relevant part: PARENT PLUS LOANS: Pursuant to the Separation Agreement, [Sobczak] is to make a good faith effort to refinance the Parent Plus loans and have [Reeves] removed from liability on the loans. [Sobczak] is ordered to pay

2 the Parent Plus loans and [Sobczak] is to indemnify and hold [Reeves] harmless thereon.

The separation and property settlement agreement stated in relevant part: [Reeves] and [Sobczak] co-signed a Parent Plus Loan for [Sobczak's] daughter. [Sobczak] is to make a good faith effort to re-finance the Parent Plus Loan or otherwise have [Reeves] removed from liability within ninety (90) days after the entry of the Judgment of Dissolution. If necessary, [Sobczak] will attempt to obtain refinancing of the loan from different lenders and will perform her due diligence in getting the loan refinanced or otherwise having [Reeves] removed from liability for the loan. In the event all the lenders indicate that refinancing of the loan is not possible, [Sobczak] will provide correspondence/documentation in writing to [Reeves] from each and every lender corroborating/verifying same. During the re-financing process, if [Sobczak] discovers another way to remove the [Reeves's] name from the Parent Plus loan without refinancing of the loan, [Sobczak] will proceed with same.

It appears that the Parent Plus loan was co-signed by both Sobczak and Reeves for Sobczak's daughter to pay for college. In August 2024, Reeves filed a motion for contempt or motion for appropriate order. Reeves asserted that Sobczak has willfully failed and refused to comply with the dissolution judgment and settlement agreement in the following relevant ways: a. By failing to make a good faith effort to re-finance the Parent Plus loan or otherwise remove [Reeves] from liability of the loan within ninety (90) days after the entry of the Judgment of Dissolution;

b. By failing to attempt to obtain refinancing through different lenders;

c. By failing to perform her due diligence in getting the Parent Plus loan refinanced or otherwise having [Reeves] removed from liability for the loan;

3 d. By failing to provide correspondence/documentation to [Reeves] as to her attempts to refinance the Parent Plus loan, including any documentation indicating that refinancing of the Parent Plus loan is not possible; and

e. By failing to make payments on the Parent Plus loan.

Reeves alleged that the Parent Plus loan had an initial balance of $18,860, that it had a balance of $46,081.27 as of the date of the dissolution, and that the loan currently has a balance of $47,392.98. The Parent Plus loan accrued $7.76 each day in interest. Reeves alleged the failure to pay the Parent Plus loan has affected her credit and caused her to incur legal fees and costs. A hearing was held on November 13, 2024. Reeves testified that, to her knowledge, "there's never been a payment on this loan ever." It is currently in deferment. For the first time in her life, Reeves was denied a credit card and a loan. The Parent Plus loan impacts her debt-income ratio. On November 13, 2024, the following docket entry was made: Order After due consideration, the Court denies the Motion for Contempt filed by [Reeves], but the Court sustains the Motion to Enforce filed by [Reeves]. [Sobczak] is ordered to provide a copy of all written documentation she has initiated or obtained regarding the consolidation of debt that results in removing the federal education loans from [Reeves's] name. This documentation shall be provided to [Reeves], through counsel, within ten (10) days. [Reeves] is awarded attorney's fees of $1,500.00, to be paid by [Sobczak] within sixty (60) days. All other court costs taxed to [Reeves]. GY 1 /Div 8 (rk) Filed By: GRETCHEN YANCEY

1 Gretchen Yancy is a Family Court Commissioner in the Thirteenth Judicial Circuit of Missouri, Division VIII.

4 (Emphasis in original). On November 15, 2024, the following docket entry was made: Ord Adopt Comisners [sic] Findings The Court adopts the findings and orders of the Family Court Commissioner this 15 th day of November, 2024. SC 2 /VII (rk)

(Emphasis in original). On November 18, 2024, Sobczak filed a motion to vacate the award of attorney fees. On December 11, 2024, the court denied that motion. On December 12, 2024, Sobczak filed a motion for findings of fact and conclusions of law. On December 16, 2024, the court denied that motion because it was not timely under Rule 73.01. This appeal follows. Jurisdiction "We have an obligation, acting sua sponte if necessary, to determine our authority to hear the appeals that come before us." Wilson v. Wilson, 640 S.W.3d 136, 140 (Mo. App. W.D. 2022). "The right to appeal is purely statutory and, where a statute does not give a right to appeal, no right exists." Id. (internal quotation marks omitted). After Sobczak filed her notice of appeal, this court sought suggestions from both parties regarding whether there was final, appealable judgment in this case. Sobczak filed suggestions arguing that the docket entry at issue is appealable pursuant to section 512.020(5), RSMo. Reeves did not file suggestions. This court permitted the appeal to

2 Sue Crane is the Family Court Administrative Judge in the Thirteenth Judicial Circuit of Missouri, Division VII.

5 proceed but asked the parties to include a discussion of the appealability of the docket entry in their respective briefs. Reeves has not filed a Respondent's Brief with this court. Section 512.020(5) states: Any party to a suit aggrieved by any judgment of any trial court in any civil cause from which an appeal is not prohibited by the constitution, nor clearly limited in special statutory proceedings, may take his or her appeal to a court having appellate jurisdiction from any ... [f]inal judgment in the case or from any special order after final judgment in the cause; but a failure to appeal from any action or decision of the court before final judgment shall not prejudice the right of the party so failing to have the action of the trial court reviewed on an appeal taken from the final judgment in the case.

(Emphasis added). "Section 512.020 ... creates three categories of appealable orders or judgments: (i) the interlocutory orders enumerated in subsections (1) through (4); (ii) final judgments; and (iii) special orders entered after final judgment." Long v. Long, 469 S.W.3d 10, 14 (Mo. App. W.D. 2015). "A special order after final judgment includes orders in special proceedings attacking or aiding the enforcement of [a] judgment after it has become final in the action in which it was rendered." Wilson, 640 S.W.3d at 140 (internal quotation marks omitted). "Orders enforcing the provisions of dissolution decrees are special orders within the meaning of § 512.020(5)." Id. In Meadowfresh Sols. USA, LLC v. Maple Grove Farms, LLC, the Missouri Supreme Court held that an appealable "order" is not a judgment and need not be denominated as such. 578 S.W.3d 758, 761–62 (Mo. banc 2019). In W. Blue Print Co., LLC v. Roberts, this court addressed the appeal of a trial court order denying a motion for

6 an order reflecting the satisfaction and release of a judgment. 696 S.W.3d 75, 77 (Mo. App. W.D. 2024). The order being appealed was a docket entry, titled "Order" and signed with the judge's typewritten initials, stating the motion to order judgment released was denied. Id. at 79. This court found that the order in the docket entry was a special order after final judgment pursuant to section 512.020(5). Id. at 79 n.6. The current case involves the appeal from a similar docket entry stating that a motion to enforce a prior final judgment is granted. This is an appeal from a special order after final judgment. This court has statutory authority to hear this appeal. Standard of Review "Appellate review of this court-tried civil case is governed by Murphy v. Carron, 536 S.W.2d 30, 32 (Mo. banc 1976)." Moore v. Moore, 484 S.W.3d 386, 389 (Mo. App. W.D. 2016). "We must affirm the trial court's judgment unless there is no substantial evidence to support it, it is against the weight of the evidence, or it erroneously declares or applies the law." Id. "Although we defer to the trial court's factual determinations, we review issues of law de novo." Id. Pro Se Appellants and Rule 84.04 "Rule 84.04 plainly sets forth the required contents of briefs filed in all appellate courts." J.R. v. P.S., 702 S.W.3d 213, 216 (Mo. App. W.D. 2024) (internal quotation marks omitted). "Compliance with Rule 84.04 is mandatory, and ensures that appellate courts do not become advocates by speculating on facts and on arguments that have not been made." Id. at 216-17 (internal quotation marks omitted). Sobczak appears pro se

7 before this court. She "is held to the same standard as attorneys and ... is subject to the requirements of Rule 84.04." Id. at 217 (internal quotation marks omitted). "Indeed, [j]udicial impartiality, judicial economy, and fairness to all parties necessitates that we do not grant pro se litigants preferential treatment with regard to their compliance with those procedural rules." Id. (internal quotation marks omitted). "As a result, the failure of an appellant, including a pro se appellant, to substantially comply with Rule 84.04, preserves nothing for our review and is grounds for dismissing the appeal." Id. (internal quotation marks omitted). Point I Sobczak's first point on appeal states, "The trial court erred in awarding counsel fees and denying Appellant's Rule 73.01 motion for findings, because § 452.355(1) requires explicit written findings on need, ability to pay, and reasonableness, in that the November 13, 2024, fee order contains no findings on any of those elements." Her argument section, in its entirety, states: Section 452.355(1) mandates that, before awarding attorney's fees in a dissolution action, the court must make written findings on (a) the need for fees, (b) each party's ability to pay, and (c) the reasonableness of the amount awarded. Nelson, 195 S.W.3d at 508–09; Hughes v. Hughes, 538 S.W.3d 901, 906 (Mo. banc 2018). The November 13, 2024, order contains none of these findings (Notice of Entry (Nov. 13, 2024) at LF 47:1–5; Notice of Entry (Nov. 15, 2024) at LF 48:1–3). Without any rationale, this Court cannot verify statutory compliance, rendering the fee award invalid. Hughes, 538 S.W.3d at 907.

Sobczak's argument is without merit. Section 452.355(1) states:

8 Unless otherwise indicated, the court from time to time after considering all relevant factors including the financial resources of both parties, the merits of the case and the actions of the parties during the pendency of the action, may order a party to pay a reasonable amount for the cost to the other party of maintaining or defending any proceeding pursuant to sections 452.300 to 452.415 and for attorney's fees, including sums for legal services rendered and costs incurred prior to the commencement of the proceeding and after entry of a final judgment. The court may order that the amount be paid directly to the attorney, who may enforce the order in the attorney's name.

This section does not contain a requirement of written findings. Nelson v. Nelson, 195 S.W.3d 502 (Mo. App. W.D. 2006) 3 does not discuss section 452.355 or attorney fees at all. Hughes v. Hughes is not found at 538 S.W.3d 901, 906-07. "The argument section of an appellate brief must provide sufficient analytical support for the claim of reversible error." J.R. v. P.S., 702 S.W.3d at 218 (internal quotation marks omitted). "It should explain how the claim of reversible error is supported by the law, and advise the appellate court how principles of law and the facts of the case interact." Id. (internal quotation marks omitted). "It is not this Court's role to parse together an argument in order to interpret the thrust of Appellants' contentions." Id. (internal quotation marks omitted). Sobczak's argument section fails to meet the requirements of Rule 84.04. Point I preserves nothing for our review. Point II Sobczak's second point on appeal states:

3 This court pulled full citations as needed from the table of authorities in Sobczak's brief.

9 The trial court erred in enforcing the decree's Parent PLUS Loan "good faith effort" clause as a fee-shifting provision, because ambiguities in a contract drafted by one party must be construed contra proferentem and cannot penalize the non-drafter, in that Respondent's counsel alone drafted the clause—providing no objective standard for "good faith effort" or "due diligence," requiring documentation only upon failure to refinance while silent on successful removal—and Commissioner Yancy admitted it was not clear and subject to differing interpretations.

Her argument section, in its entirety, states: The decree requires Respondent to "make a good faith effort to refinance the Parent PLUS Loan or otherwise have Petitioner removed from liability within ninety (90) days," but provides no objective criteria for "good faith" or what "due diligence" entails, and only mandates documentation upon failure to refinance. Under Missouri law, ambiguities in a contract drafted by one party are construed against the drafter and not used to penalize the non-drafter. In re Marriage of Pate, 201 S.W.3d 875, 879 (Mo. App. 2006); Cohen v. Cohen, 73 S.W.3d 39, 43 (Mo. banc 2002). Commissioner Yancy admitted on the record that the clause was not clear when she stated, "I understand" upon challenge of the language by the Appellant, and subject to differing interpretations (Tr. 20:5–7). Construing contra proferentem, Appellant—who did not draft or negotiate the clause—cannot be held liable for fees to enforce an ambiguous obligation.

Sobczak's argument is without merit. In re Marriage of Pate is not found at 201 S.W.3d

1. While Cohen v. Cohen is located at 73 S.W.3d 39, page 43 contains only summaries

of various topics in the opinion. The substance of the opinion does not begin until page

Page 20 of the transcript contains the following: THE COURT: ... I think it's in everybody's best interest for the Court to be really clear about who's going to be responsible for this debt, whether it's 50/50 or one party or the other. Now, if you refinance this debt and only your name is on it –

10

SOBCZAK: Right.

THE COURT: -- then you're fully responsible.

SOBCZAK: Correct. But if the lender allowed that, yes, but if the lender doesn't allow that, then we both have that loan. It's –

THE COURT: But you will not because the Court is required to divide it. So I am going to assign responsibility for it. And as I understand the testimony, even though this was for the daughter's education, she is not actually personally responsible for it.

SOBCZAK: That's correct.

This transcript excerpt does not a support a contention that the court found that the dissolution judgment was ambiguous. As in Point I, this argument section fails to meet the requirements of Rule 84.04. Point II preserves nothing for our review. Point III Sobczak's third point on appeal states: The trial court erred in enforcing an ambiguous decree provision by motion to enforce rather than by modification under § 452.325, because § 452.325 provides the exclusive procedure for altering a final decree and mandates notice and a hearing on changed circumstances, in that Respondent bypassed that procedure and obtained fee relief via contempt/enforcement.

Her argument section, in its entirety, states: Section 452.325 provides the exclusive mechanism for modifying a final dissolution decree, requiring notice to the opposing party and a hearing on changed circumstances. Norman, 941 S.W.2d at 769–70; Krane v. Krane, 625 S.W.2d 585, 587 (Mo. banc 1981). Respondent instead filed a motion

11 to enforce an ambiguous term and sought contempt sanctions (Tr. 18:3–10). By bypassing § 452.325, the court denied Appellant her statutory right to proper notice and a modification hearing, rendering the enforcement action procedurally defective.

Section 452.325 states:

1. To promote the amicable settlement of disputes between the parties to a

marriage attendant upon their separation or the dissolution of their marriage, the parties may enter into a written separation agreement containing provisions for the maintenance of either of them, the disposition of any property owned by either of them, and the custody, support and visitation of their children.

1. In a proceeding for dissolution of marriage or for legal separation, the

terms of the separation agreement, except terms providing for the custody, support, and visitation of children, are binding upon the court unless it finds, after considering the economic circumstances of the parties and any other relevant evidence produced by the parties, on their own motion or on request of the court, that the separation agreement is unconscionable.

1. If the court finds the separation agreement unconscionable, the court may

request the parties to submit a revised separation agreement or the court may make orders for the disposition of property, support, and maintenance in accordance with the provisions of sections 452.330, 452.335 and 452.340.

1. If the court finds that the separation agreement is not unconscionable as

to support, maintenance, and property: (1) Unless the separation agreement provides to the contrary, its terms shall be set forth in the decree of dissolution or legal separation and the parties shall be ordered to perform them; or (2) If the separation agreement provides that its terms shall not be set forth in the decree, only those terms concerning child support, custody and visitation shall be set forth in the decree, and the decree shall state that the court has found the remaining terms not unconscionable.

1. Terms of the agreement set forth in the decree are enforceable by all

remedies available for the enforcement of a judgment, and the court may

12 punish any party who willfully violates its decree to the same extent as is provided by law for contempt of the court in any other suit or proceeding cognizable by the court.

1. Except for terms concerning the support, custody or visitation of

children, the decree may expressly preclude or limit modification of terms set forth in the decree if the separation agreement so provides.

This section does not discuss notice or a hearing on changed circumstances. Norman v. Norman is not found at 941 S.W.2d 766, 769-70. Krane v. Krane is not found at 625 S.W.2d 585, 587. As in Points I and II, this argument section fails to meet the requirements of Rule 84.04. Point III preserves nothing for our review. Point IV Sobczak's fourth point on appeal states: The trial court erred in entering a post-judgment fee award more than thirty days after final judgment, because Rule 75.01 and § 512.020 limit a court's jurisdiction to enter a money judgment to the 30-day period following entry of final decree, in that the decree was entered on February 28, 2024 and the fee order was docketed on November 13, 2024—well beyond the thirty-day window.

Her argument section, in its entirety, states: Rule 75.01 and § 512.020 strictly limit a court's power to enter a money judgment [after] the 30-day period after a final decree. Callahan, 277 S.W.3d at 647; State ex rel. Wright v. Campbell, 499 S.W.3d 361, 364 (Mo. banc 2016). The decree issued February 28, 2024, but the fee order was docketed November 13, 2024—over eight months later (Docket Sheet Nov. 13 entry). That order is void for lack of jurisdiction.

Section 512.020 states:

13 Any party to a suit aggrieved by any judgment of any trial court in any civil cause from which an appeal is not prohibited by the constitution, nor clearly limited in special statutory proceedings, may take his or her appeal to a court having appellate jurisdiction from any:

(1) Order granting a new trial;

(2) Order refusing to revoke, modify, or change an interlocutory order appointing a receiver or receivers, or dissolving an injunction;

(3) Order granting or denying class action certification provided that: (a) The court of appeals, in its discretion, permits such an appeal; and (b) An appeal of such an order shall not stay proceedings in the court unless the judge or the court of appeals so orders;

(4) Interlocutory judgments in actions of partition which determine the rights of the parties; or

(5) Final judgment in the case or from any special order after final judgment in the cause; but a failure to appeal from any action or decision of the court before final judgment shall not prejudice the right of the party so failing to have the action of the trial court reviewed on an appeal taken from the final judgment in the case.

It does not discuss the court's power after a thirty-day period or money judgments. In re Marriage of Callahan, 277 S.W.3d 643 (Mo. banc 2009) ends on page 646 and does not exist on page 647. Moreover, Callahan does not discuss Rule 75.01, section 512.020, a thirty-day period, or a money judgment. Wright v. Campbell is not found at 499 S.W.3d

Rule 75.01 states: Except as otherwise provided in Rule 81.045, the trial court retains control over judgments during the 30-day period after entry of judgment and may, after giving the parties an opportunity to be heard and for good cause,

14 vacate, reopen, correct, amend, or modify its judgment within that time. Not later than 30 days after entry of judgment, the court of its own initiative may order a new trial for any reason for which it might have granted a new trial on motion of a party, and every order granting a new trial shall specify the grounds therefor. After the filing of notice of appeal and before the filing of the record on appeal in the appellate court, the trial court, after the expiration of such 30-day period, may still vacate, amend or modify its judgment upon stipulation of the parties accompanied by a withdrawal of the appeal.

The 30-day period after entry of judgment for granting a new trial of the court's own initiative is not shortened by the filing of a notice of appeal but is terminated when the record on appeal is filed in the appellate court or an order shortening this period is entered under Rule 81.045.

With respect to Rule 75.01, Sobczak does not address a number of pertinent issues. These include whether a motion to enforce a judgment is a separate action, whether it has its own deadlines, and whether it must be made within a certain time frame after the judgment to be enforced is entered. As noted above, "the argument section of an appellate brief must provide sufficient analytical support for the claim of reversible error." Hicks v. Northland- Smithville, 655 S.W.3d 641, 649 (Mo. App. W.D. 2022). "An argument must explain why, in the context of the case, the law supports the claim of reversible error. It should advise the appellate court how principles of law and the facts of the case interact." Id. (internal quotation marks omitted). Here, Sobczak has recited the law and then stated conclusions as to why her claim fits within such a claim. Though her arguments include conclusory claims of error, the remainder of her arguments "merely rest on broad brush strokes which generalize [her]

15 complaints[,] and entirely fail to develop an argument by demonstrating how the principles of law and the facts of the present case interact to support [her] assertion that the trial court committed reversible error." Id. (internal quotation marks and citation omitted). We cannot complete Sobczak's arguments for her. "It is not our duty or responsibility to spend judicial time searching through the argument portions of briefs in an attempt to interpret the thrust of [Appellants'] contentions." Id. (internal quotation marks omitted). "Rather, [t]he Appellants' argument must tie the legal principles together with the facts at hand in order to make their argument." Id. (internal quotation marks omitted). We cannot comb the legal file for facts to better understand Sobczak's argument, "nor can we do so and remain steadfast to our role as the neutral arbiter of the case." Id. (internal quotation marks omitted). As such, Sobczak has failed to "satisfy the fundamental requirement of an appellate argument, which is to demonstrate the erroneousness of the basis upon which the lower court issued an adverse ruling." Id. (internal quotation marks omitted). "Her arguments fail to provide appropriate analytical support for her claims of reversible error, nor do they clarify the grounds on which she claims reversible error." Id. Sobczak has not "failed to clearly state wherein and why the trial court erred, meaning she has also failed to present a readily understandable argument sufficient to give notice to the opposing party of the precise matters which must be contended with and to inform the court of the issues presented for review. " Id. at 649-50 (internal quotation marks omitted).

16 Point IV preserves nothing for our review. Point V Sobczak's fifth point on appeal states: The trial court erred in converting the decree's clear, disjunctive "refinance or remove liability within ninety days" clause into an indefinite obligation, because Missouri law treats a plainly disjunctive obligation as self- extinguishing upon its deadline, in that the court imposed enforcement sanctions more than ninety days after entry of the decree.

Her argument section, in its entirety, states: The decree imposes two alternative obligations— "refinance or remove liability within ninety (90) days"—and contains no provision extending that deadline. Judgment & Decree at LF 19:13–23. Under Haynes, 277 S.W.3d at 745, and Edwards, 237 S.W.3d at 582, such disjunctive duties expire when their deadline passes. Yet the court sanctioned Appellant for enforcement well after ninety days (Tr. 18:15–19), effectively rewriting the parties' agreement and violating the plain‐language rule.

Haynes v. Haynes is not found at 277 S.W.3d 743, 745. Edwards v. Gerstein, 237 S.W.3d 580 (Mo. banc 2007), does not discuss disjunctive duties, expiration dates, or deadlines. As with the prior points, this argument section fails to meet the requirements of Rule 84.04. Point V preserves nothing for our review. Point VI Sobczak's sixth point on appeal states: The trial court erred in granting enforcement relief without first providing ten days' notice under Rule 74.03 or proceeding by vacatur under Rule 75.01, because those rules guarantee procedural protections for contempt and post-judgment relief, in that on November 13, 2024, the court denied

17 the contempt motion but nonetheless sustained enforcement and awarded fees without any required notice or vacatur motion.

Her argument section, in its entirety, states: Rule 74.03 requires at least ten days' written notice before contempt proceedings. Haug, 784 S.W.2d at 843. Rule 75.01 mandates vacatur procedures for any post-judgment relief. State ex rel. Div. of Family Servs. v. Gutenkauf, 835 S.W.2d 237, 239 (Mo. banc 1992). On November 13, 2024, the docket reflects that Commissioner Yancy "Denied Motion for Contempt; Granted Motion to Enforce" (Docket, Nov. 13 entry, LF 3–18). The Notice of Entry filed that same day confirms the enforcement order and fee award (Notice of Entry (Nov. 13, 2024) at LF 47:1–5). Neither the docket nor the notice shows any ten-day notice or vacatur motion having been made (Docket, Nov. 13 entry, LF 3–18; Notice of Entry, Nov. 13, 2024, LF 47:1–5), depriving Appellant of fundamental due process.

Rule 74.03 states: Immediately upon the entry of an order or judgment, the clerk shall serve a notice of the entry by mail in the manner provided for in Rule 43.01 upon each party who is not in default for failure to appear and who was not present in court in person or by attorney at the time of the entry of such order or judgment. If such notice is not given, the order or judgment shall be set aside for good cause shown upon written motion filed within six months from the entry of the order or judgment. This Rule 74.03 shall not preclude relief under Rule 74.06.

It does not contain a ten-day notice provision for contempt proceedings. Rule 75.01 is set out in Point IV. It does not "mandate[] vacatur procedures for any post-judgment relief." In re Marriage of Haug is not found at 784 S.W.2d 841, 843. State ex rel. Div. of Family Servs. v. Gutenkauf is not found at 835 S.W.2d 237, 239. As with the prior points, this argument section fails to meet the requirements of Rule 84.04. Point VI preserves nothing for our review.

18 Point VII Sobczak's seventh point on appeal states: The trial court erred in enforcing the Parent PLUS provision after the commissioner admitted its ambiguity, because judicial admissions bind the court and estop enforcement of ambiguous terms, in that Commissioner Yancy orally acknowledged she understood the clause was not clear and subject to differing interpretations at the November 13, 2024, hearing.

Her argument section, in its entirety, states: A judicial officer's statements constitute binding admissions. Cottingham, 470 S.W.3d at 146. Commissioner Yancy conceded the clause was not clear when stating, "I understand" when the language was challenged (Tr. 20:5– 7). Under Crawford v. Crawford, 291 S.W.3d 483, 486 (Mo. App. W.D. 2009), Respondent is estopped from enforcing a term the court itself found ambiguous.

Pacific Employers Ins. Co. v. Cottingham is not found at 470 S.W.3d 140, 146. Crawford v. Crawford is not found at 291 S.W.3d 483, 486. As with the prior points, this argument section fails to meet the requirements of Rule 84.04. Point VII preserves nothing for our review.

19 Conclusion Sobczak's brief does not comply with Rule 84.04. She does not cite cases or statutes relevant to her points on appeal. She does not provide sufficient analytical support for her claims of reversible error. None of Sobczak's points on appeal preserve anything for this court to review. The appeal is dismissed.

____________________________ Anthony Rex Gabbert, Chief Judge

All concur.