In In re Estate of Earnest E. Clifton, an applicant offered a copy of a lost will, and the trial court denied the application via a zoom hearing without a court reporter. No. 05-24-00079-CV, 2024 Tex. App. LEXIS 7071 (Tex. App.—Dallas October 1, 2024, no pet.). The applicant appealed on multiple evidentiary complaints. The court of appeals affirmed the order due to the absence of a reporter’s record:

“It is the appellant’s burden to bring forward an appellate record showing reversible error by the trial court.” Without a complete reporter’s record, we cannot review all of the evidence presented to the factfinder or apply the sufficiency standards of review. Thus, when the appellant fails to bring a complete reporter’s record forward on appeal, the reviewing court must presume that the evidence was legally and factually sufficient to support the challenged order or judgment. The absence of a reporter’s record requires us to overrule Pearson’s first, second, and fourth issues, each of which is essentially a sufficiency-of-the-evidence issue.

Id. (internal citations omitted). The court then reviewed a complaint about the trial court conducting its own research and relying on same, but the court held that the applicant waived this complaint by failing to adequately brief it. The court affirmed the order.