necessary corollary rule in California

2026“Appealed judgments and orders are presumed correct, and error must be affirmatively shown. [Citation.] Consequently, [the appellant] has the burden of providing an adequate record. [Citation.] Failure to provide an adequate record on an issue requires that issue be resolved against [the appellant].” (Hernandez v. California Hospital Medical Center (2000) 78 Cal.App.4th 498, 502 ; see also Osgood v. Landon (2005) 127 Cal.App.4th 425, 435 [“It is the appellant’s affirmative duty to show error by an adequate record.”]; Mountain Lion Coalition v. Fish & Game Com. (1989) 214 Cal.App.3d 1043, 1051,

2024All intendments and presumptions are indulged to support it on matters as to which the record is silent, and error must be affirmatively shown.” (Denham v. Superior Court (1970) 2 Cal.3d 557, 564 ; see also Srithong v. Total Investment Co. (1994) 23 Cal.App.4th 721, 725, fn. 3 [“It was of course the duty of Srithong, as the appellant, to furnish an adequate record for review.”].) “A necessary corollary to this rule is that if the record is inadequate for meaningful review, the appellant defaults and the decision of the trial court should be affirmed.” (Mountain Lion Coalition v. Fish & Game Co

2026A judgment “is ordinarily presumed to be correct and the burden is on an appellant to demonstrate, on the basis of the record presented to the appellate court, that the trial court committed an error that justifies reversal of the judgment.” (Jameson v. Desta (2018) 5 Cal.5th 594, 609 (Jameson).) “ ‘In the absence of a contrary showing in the record, all presumptions in favor of the trial court’s action will be made by the appellate court.’ ” (Ibid.) “ ‘ “A necessary corollary to this rule is that if the record is inadequate for meaningful review, the appellant defaults and the decision of the

2026We Decline to Treat the Appeal as Forfeited for OneUnited’s Failure to Provide a Complete Record “[I]t is a fundamental principle of appellate procedure that a trial court judgment is ordinarily presumed to be correct and the burden is on an appellant to demonstrate, on the basis of the record presented to the appellate court, that the trial court committed an error that justifies reversal of the judgment. [Citations.] . . . ‘In the absence of a contrary showing in the record, all presumptions in favor of the trial court’s action will be made by the appellate court. . . .’ [Citation.] ‘ “A nec

2026It is a cardinal rule of appellate review that a “trial court judgment is ordinarily presumed to be correct and the burden is on an appellant to demonstrate, on the basis of the record presented to the appellate court, that the trial court committed an error that justifies reversal of the judgment.” (Jameson v. Desta (2018) 5 Cal.5th 594, 609 (Jameson).) “ ‘A necessary corollary to this rule is that if the record is inadequate for meaningful review, the appellant defaults and the decision of the trial court should be affirmed.’ ” (Gee v. American Realty & Construction, Inc. (2002) 99 Cal.App.4

2025(Hernandez v. First Student, Inc. (2019) 37 Cal.App.5th 270, 277 ; Nwosu v. Uba (2004) 122 Cal.App.4th 1229, 1246 .) “ ‘A necessary corollary to this rule is that if the record is inadequate for meaningful review, the appellant defaults and the decision of the trial court should be affirmed.’ ” (Gee v. American Realty & Construction, Inc. (2002) 99 Cal.App.4th 1412, 1416 ; accord, Maria P. v. Riles (1987) 43 Cal.3d 1281, 1295-1296 .) Here, Qadeer elected to provide a record of the documents filed in the superior court via an appendix, pursuant to rule 8.124.

2025(Denham v. Superior Court (1970) 2 Cal.3d 557 , 564 . . . .) ‘In the absence of a contrary showing in the record, all presumptions in 3 favor of the trial court’s action will be made by the appellate court. “[I]f any matters could have been presented to the court below which would have authorized the order complained of, it will be presumed that such matters were presented.” ’ ” (Foust v. San Jose Construction Co., Inc. (2011) 198 Cal.App.4th 181, 187 .) “An appellant has the burden to overcome the presumption of correctness and show prejudicial error.” (Silva v. See’s Candy Shops, Inc. (2016)

2025(Denham v. Superior Court (1970) 2 Cal.3d 557, 564 .) ‘In the absence of a contrary showing in the record, all presumptions in favor of the trial court’s action will be made by the appellate court. . . .’ ‘ “A necessary corollary to this rule is that if the record is inadequate for meaningful review, the appellant defaults and the decision of the trial court should be affirmed.” ” [Citation.] ‘Consequently, [appellant] has the burden of providing an adequate record. [Citation.] Failure to provide an adequate record on an issue requires that the issue be resolved against [appellant].’ ” (Foust

2025The matter was fully briefed in July 2025 and assigned to this panel in August 2025. 3 DISCUSSION I Appellate Rules of Procedure “It is well settled . . . that a party challenging a judgment has the burden of showing reversible error by an adequate record.” (Ballard v. Uribe (1986) 41 Cal.3d 564, 574 .) “ ‘ “A necessary corollary to this rule is that if the record is inadequate for meaningful review, the appellant defaults and the decision of the trial court should be affirmed.” ’ ” (Jameson v. Desta (2018) 5 Cal.5th 594, 609 (Jameson) [failure to provide an adequate record on an issue require

2025However, this would not be beneficial as we conclude, post, the record is inadequate on appeal to review her claims. 4 of appellate practice but an ingredient of the constitutional doctrine of reversible error.’ [Citations.] ‘In the absence of a contrary showing in the record, all presumptions in favor of the trial court’s action will be made by the appellate court.’ ” (Jameson v. Desta (2018) 5 Cal.5th 594, 608-609 .) “ ‘ “A necessary corollary to this rule is that if the record is inadequate for meaningful review, the appellant defaults and the decision of the trial court should be affirmed.

2026This is not only a general principle of appellate practice but an ingredient of the constitutional doctrine of reversible error.’ [Citations.]” (Denham v. Superior Court (1970) 2 Cal.3d 557, 564 , italics omitted.) “ ‘In the absence of a contrary showing in the record, all presumptions in favor of the trial court’s action will be made by the appellate court. . . . [Citation.] “ ‘ “A necessary corollary to this rule is that if the record is inadequate for meaningful review, the appellant defaults and the decision of the trial court should be affirmed.” ’ [Citation.] ‘Consequently, [the appellan

2025(Denham v. Superior Court (1970) 2 Cal.3d 557 , 564 . . . .) ‘In the absence of a contrary showing in the record, all presumptions in 3 favor of the trial court’s action will be made by the appellate court. “[I]f any matters could have been presented to the court below which would have authorized the order complained of, it will be presumed that such matters were presented.” ’ ” (Foust v. San Jose Construction Co., Inc. (2011) 198 Cal.App.4th 181, 187 .) “An appellant has the burden to overcome the presumption of correctness and show prejudicial error.” (Silva v. See’s Candy Shops, Inc. (2016)

2026“Appealed judgments and orders are presumed correct, and error must be affirmatively shown. [Citation.] Consequently, [the appellant] has the burden of providing an adequate record. [Citation.] Failure to provide an adequate record on an issue requires that issue be resolved against [the appellant].” (Hernandez v. California Hospital Medical Center (2000) 78 Cal.App.4th 498, 502 ; see also Osgood v. Landon (2005) 127 Cal.App.4th 425, 435 [“It is the appellant’s affirmative duty to show error by an adequate record.”]; Mountain Lion Coalition v. Fish & Game Com. (1989) 214 Cal.App.3d 1043, 1051,

2025VI, § 13.) ‘In the absence of a contrary showing in the record, all presumptions in favor of the trial court’s action will be made by the appellate court. “[I]f any matters could have been presented to the court below which would have authorized the order complained of, it will be presumed that such matters were presented.” ’ (Bennett v. McCall (1993) 19 Cal.App.4th 122, 127 [].) ‘ “A necessary corollary to this rule is that if the record is inadequate for meaningful review, the appellant defaults and the decision of the trial court should be affirmed.” ’ (Gee v. American Realty & Construction

2014This is not only a general principle of appellate practice but an ingredient of the constitutional doctrine of reversible error.’” ( Denham v. Superior Court (1970) 2 Cal.3d 557, 564 .) “‘A necessary corollary to this rule is that if the record is inadequate for meaningful review, the appellant defaults and the decision of the trial court should be affirmed.’ (Mountain Lion Coalition v. Fish & Game Com. (1989) 214 Cal.App.3d 1043, 1051, fn. 9 ; accord, Estrada v. Ramirez (1999) 71 Cal.App.4th 618, 620, fn. 1 ).” (Gee v. American Realty & Construction, Inc. (2002) 99 Cal. App 4th 1412, 1416.) I

2013(Estate of Beard (1999) 71 Cal.App.4th 753, 776-777 ; D’Amico v. Board of Medical Examiners (1974) 11 Cal.3d 1, 18-19 .)” (Cahill v. San Diego Gas & Electric Co. (2011) 194 Cal.App.4th 939, 956 .) “„A necessary corollary to this rule is that if the record is inadequate for meaningful review, the appellant defaults and the decision of the trial court should be affirmed.‟ (Mountain Lion Coalition v. Fish & Game Com. (1989) 214 Cal.App.3d 1043, 1051, fn. 9 ; accord, Estrada v. Ramirez (1999) 71 Cal.App.4th 618, 620, fn. 1 .)” (Gee v. American Realty & Construction, Inc. (2002) 99 Cal.App.4th 1412

2025(See Jameson, supra, at p. 609 .) “ ‘ “A necessary corollary to this rule is that if the record is inadequate for meaningful review, the appellant defaults and the decision of the trial court should be affirmed.” ’ [Citation.] ‘Consequently, [the appellant] has the burden of providing an adequate record. [Citation.] Failure to provide an adequate record on an issue requires that the issue be resolved against [the appellant].’ [Citation.]” (Jameson, supra, 5 Cal.5th at p. 609 , fn. omitted; see also Maria P. v. Riles (1987) 43 Cal.3d 1281 , 1295–1296 [“Because they failed to furnish an adequate

2025(Hernandez v. First Student, Inc. (2019) 37 Cal.App.5th 270, 277 ; Nwosu v. Uba (2004) 122 Cal.App.4th 1229, 1246 .) “ ‘A necessary corollary to this rule is that if the record is inadequate for meaningful review, the appellant defaults and the decision of the trial court should be affirmed.’ ” (Gee v. American Realty & Construction, Inc. (2002) 99 Cal.App.4th 1412, 1416 ; accord, Maria P. v. Riles (1987) 43 Cal.3d 1281, 1295-1296 .) Here, Qadeer elected to provide a record of the documents filed in the superior court via an appendix, pursuant to rule 8.124.

2026“Appealed judgments and orders are presumed correct, and error must be affirmatively shown. [Citation.] Consequently, [the appellant] has the burden of providing an adequate record. [Citation.] Failure to provide an adequate record on an issue requires that issue be resolved against [the appellant].” (Hernandez v. California Hospital Medical Center (2000) 78 Cal.App.4th 498, 502 ; see also Osgood v. Landon (2005) 127 Cal.App.4th 425, 435 [“It is the appellant’s affirmative duty to show error by an adequate record.”]; Mountain Lion Coalition v. Fish & Game Com. (1989) 214 Cal.App.3d 1043, 1051,

2025Even Absent Forfeiture, the Record Is Inadequate to Show Error We also conclude that, even in the absence of forfeiture, the record on appeal is inadequate to show error warranting reversal. “[I]t is a fundamental principle of appellate procedure that a trial court judgment is ordinarily presumed to be correct and the burden is on an appellant to demonstrate, on the basis of the record presented to the appellate court, that the trial court committed an error that justifies reversal of the judgment.” (Jameson v. Desta (2018) 5 Cal.5th 594, 608-609 .) “‘“A necessary corollary to this rule is tha

2025DISCUSSION I Appellate Rules of Procedure “It is well settled . . . that a party challenging a judgment [or order] has the burden of showing reversible error by an adequate record.” (Ballard v. Uribe (1986) 41 Cal.3d 564, 574 .) “ ‘ “A necessary corollary to this rule is that if the record is inadequate for meaningful review, the appellant defaults and the decision of the trial court should be affirmed.” ’ ” (Jameson v. Desta (2018) 5 Cal.5th 594, 609 (Jameson) [failure to provide an adequate record on an issue requires that the issue be resolved against the appellant]; see Jade Fashion & Co.,

2025The matter was fully briefed in July 2025 and assigned to this panel in August 2025. 3 DISCUSSION I Appellate Rules of Procedure “It is well settled . . . that a party challenging a judgment has the burden of showing reversible error by an adequate record.” (Ballard v. Uribe (1986) 41 Cal.3d 564, 574 .) “ ‘ “A necessary corollary to this rule is that if the record is inadequate for meaningful review, the appellant defaults and the decision of the trial court should be affirmed.” ’ ” (Jameson v. Desta (2018) 5 Cal.5th 594, 609 (Jameson) [failure to provide an adequate record on an issue require

2025VI, § 13.) ‘In the absence of a contrary showing in the record, all presumptions in favor of the trial court’s action will be made by the appellate court. “[I]f any matters could have been presented to the court below which would have authorized the order complained of, it will be presumed that such matters were presented.” ’ (Bennett v. McCall (1993) 19 Cal.App.4th 122, 127 [].) ‘ “A necessary corollary to this rule is that if the record is inadequate for meaningful review, the appellant defaults and the decision of the trial court should be affirmed.” ’ (Gee v. American Realty & Construction

2022VI, § 13.) ‘In the absence of a contrary showing in the record, all presumptions in favor of the trial court’s action will be made by the appellate court. “[I]f any matters could have been presented to the court below which would have authorized the order complained of, it will be presumed that such matters were presented.” ’ (Bennett v. McCall (1993) 19 Cal.App.4th 122, 127 [].) ‘ “A necessary corollary to this rule is that if the record is inadequate for meaningful review, the appellant defaults and the decision of the trial court should be affirmed.” ’ (Gee v. American Realty & Construction

2021(In re Marriage of F.M. and M.M. (2021) 65 Cal.App.5th 106 , 110, fn. 1 [the “appellant ‘still bears the “affirmative burden to show error whether or not the respondent’s brief has been filed” ’ ”].) Correspondingly, as the party seeking review, Appellant has “the burden to provide sufficient record to show error.” (In re Marriage of Brewster & Clevenger (2020) 45 Cal.App.5th 481 , 511; accord, Jameson, supra, 5 Cal.5th at p. 609 .) “ ‘ “A necessary corollary to this rule is that if the record is inadequate for meaningful review, the appellant defaults and the decision of the trial court shoul

2016This is not only a general principle of appellate practice but an ingredient of the constitutional doctrine of reversible error.' " (Denham v. Superior Court (1970) 2 Cal.3d 557, 564 .) "It is well settled, of course, that a party challenging a judgment [or order] has the burden of showing reversible error by an adequate record." (Ballard v. Uribe (1986) 41 Cal.3d 564, 574 .) "A necessary corollary to this rule is that if the record is inadequate for meaningful review, the appellant defaults and the decision of the trial court should be affirmed." (Mountain Lion Coalition v. Fish & Game Com. (

2026The appellant must present an adequate argument including citations to supporting authorities and to relevant portions of the record.’” (L.O. v. Kilrain (2023) 96 Cal.App.5th 616 , 619–620.) To overcome the presumption the judgment is correct, “the appellant must provide an adequate appellate record demonstrating error. [Citation.] ‘“A necessary corollary to this rule [is] that a record is inadequate . . . if the appellant predicates error only on the part of the record he [or she] provides the trial court, but ignores or does not present to the appellate court portions of the proceedings belo

2025The matter was fully briefed in July 2025 and assigned to this panel in August 2025. 3 DISCUSSION I Appellate Rules of Procedure “It is well settled . . . that a party challenging a judgment has the burden of showing reversible error by an adequate record.” (Ballard v. Uribe (1986) 41 Cal.3d 564, 574 .) “ ‘ “A necessary corollary to this rule is that if the record is inadequate for meaningful review, the appellant defaults and the decision of the trial court should be affirmed.” ’ ” (Jameson v. Desta (2018) 5 Cal.5th 594, 609 (Jameson) [failure to provide an adequate record on an issue require

2025(See Jameson, supra, 5 Cal.5th at p. 609 .) “ ‘ “A necessary corollary to this rule is that if the record is inadequate for meaningful review, the appellant defaults and the decision of the trial court should be affirmed.” ’ [Citation.] ‘Consequently, [the appellant] has the burden of providing an adequate record. [Citation.] Failure to provide an adequate record on an issue requires that the issue be resolved against [the appellant].’ [Citation.]” (Jameson, supra, 5 Cal.5th at p. 609 , fn. omitted.) Accordingly, “in the absence of a required reporter’s transcript and other documents, we presu

2022(Maria P. v. Riles (1987) 43 Cal.3d 1281 , 1295–1296 (Maria P.) “[I]n the absence of a required reporter’s transcript and other [relevant] documents, we presume 15 the judgment is correct.” (Stasz v. Eisenberg (2010) 190 Cal.App.4th 1032, 1039 (Stasz).) “‘A necessary corollary to this rule [is] that a record is inadequate, and appellant defaults, if the appellant predicates error only on the part of the record he provides the trial court, but ignores or does not present to the appellate court portions of the proceedings below which may provide grounds upon which the decision of the trial court

2023This is not only a general principle of appellate practice but an ingredient of the constitutional doctrine of reversible error.’ ” (Denham v. Superior Court (1970) 2 Cal.3d 557, 564 .) “ ‘A necessary corollary to this rule is that if the record is inadequate for meaningful review, the appellant defaults and the decision of the trial court should be 6 affirmed.’ ” (Gee v. American Realty & Construction, Inc. (2002) 99 Cal.App.4th 1412, 1416 ; see also Aguilar v. Avis Rent A Car System, Inc. (1999) 21 Cal.4th 121, 132 [where the defendants elected not to provide a reporter’s transcript on appea

2013This is not only a general principle of appellate practice but an ingredient of the constitutional doctrine of reversible error.‟ [Citations.]” (Denham v. Superior Court (1970) 2 Cal.3d 557, 564 , italics in the original.) “ „A necessary corollary to this rule is that if the record is inadequate for meaningful review, the appellant defaults and the decision of the trial court should be affirmed.‟ [Citations.]” (Gee v. American Realty & Construction, Inc. (2002) 99 Cal.App.4th 1412, 1416 ; see also Aguilar v. Avis Rent A Car System, Inc. (1999) 21 Cal.4th 121, 132 [where the defendants elected

2022“All intendments and presumptions are indulged to support [the judgment] on matters as to which the record is silent, and error must be affirmatively shown.” (Denham v. Superior Court (1970) 2 Cal.3d 557, 564 ; In re Marriage of Arceneaux (1990) 51 Cal.3d 1130, 1133 .) Therefore, a party challenging a judgment or an appealable order “has the burden of showing reversible error by an adequate record.” (Ballard v. Uribe (1986) 41 Cal.3d 564, 574 .) “ ‘A necessary corollary to this rule is that if the record is inadequate for meaningful review, the appellant defaults and the decision of the trial

2016(Denham v. Superior Court (1970) 2 Cal.3d 557, 564 [“‘All intendments and presumptions are indulged to support [the judgment] on matters as to which the record is silent, and error must be affirmatively shown.’”]; see also In re Marriage of Arceneaux (1990) 51 Cal.3d 1130, 1133 .) Thus, a party challenging a 4. judgment or an appealable order “has the burden of showing reversible error by an adequate record.” (Ballard v. Uribe (1986) 41 Cal.3d 564, 574 .) “‘A necessary corollary to this rule is that if the record is inadequate for meaningful review, the appellant defaults and the decision of t

2025DISCUSSION I Appellate Rules of Procedure “It is well settled . . . that a party challenging a judgment [or order] has the burden of showing reversible error by an adequate record.” (Ballard v. Uribe (1986) 41 Cal.3d 564, 574 .) “ ‘ “A necessary corollary to this rule is that if the record is inadequate for meaningful review, the appellant defaults and the decision of the trial court should be affirmed.” ’ ” (Jameson v. Desta (2018) 5 Cal.5th 594, 609 (Jameson) [failure to provide an adequate record on an issue requires that the issue be resolved against the appellant]; see Jade Fashion & Co.,

2025The matter was fully briefed in July 2025 and assigned to this panel in August 2025. 3 DISCUSSION I Appellate Rules of Procedure “It is well settled . . . that a party challenging a judgment has the burden of showing reversible error by an adequate record.” (Ballard v. Uribe (1986) 41 Cal.3d 564, 574 .) “ ‘ “A necessary corollary to this rule is that if the record is inadequate for meaningful review, the appellant defaults and the decision of the trial court should be affirmed.” ’ ” (Jameson v. Desta (2018) 5 Cal.5th 594, 609 (Jameson) [failure to provide an adequate record on an issue require

2025(Hernandez v. First Student, Inc. (2019) 37 Cal.App.5th 270, 277 ; Nwosu v. Uba (2004) 122 Cal.App.4th 1229, 1246 .) “ ‘A necessary corollary to this rule is that if the record is inadequate for meaningful review, the appellant defaults and the decision of the trial court should be affirmed.’ ” (Gee v. American Realty & Construction, Inc. (2002) 99 Cal.App.4th 1412, 1416 ; accord, Maria P. v. Riles (1987) 43 Cal.3d 1281, 1295-1296 .) Here, Qadeer elected to provide a record of the documents filed in the superior court via an appendix, pursuant to rule 8.124.

2024(Hernandez v. First Student, Inc. (2019) 37 Cal.App.5th 270, 277 ; Nwosu v. Uba (2004) 122 Cal.App.4th 1229, 1246 .) “ ‘A necessary corollary to this rule is that if the record is inadequate for meaningful review, the appellant defaults and the decision of the trial court should be affirmed.’ ” (Gee v. American Realty & Construction, Inc. (2002) 99 Cal.App.4th 1412, 1416 .) Here, Tsang elected to provide a record of the documents filed in the superior court via an appendix, pursuant to California 4 Rules of Court, rule 8.124.2 But her appendix lacks much of what is required by the rules.

2020(State Farm Fire & Casualty Co. v. Pietak (2001) 90 Cal.App.4th 600 , 610 . . . .) ‘ “A necessary corollary to this rule is that if the record is inadequate for meaningful review, the appellant defaults and the decision of the trial court should be 11 affirmed.” ’ (Gee v. American Realty & Construction, Inc. (2002) 99 Cal.App.4th 1412 , 1416 . . . .)” (Foust v. San Jose Construction Co., Inc. (2011) 198 Cal.App.4th 181, 187 .) C.

2015(State Farm Fire & Casualty Co. v. Pietak (2001) 90 Cal.App.4th 600, 610 .) " 'A necessary corollary to this rule is that if the record is inadequate for meaningful review, the appellant defaults and the decision of the trial court should be affirmed.' " (Gee v. American Realty & Construction, Inc. (2002) 99 Cal.App.4th 1412, 1416 .) "Consequently, [appellant] has the burden of providing an adequate record. [Citation.] Failure to provide an adequate record on an issue requires that the issue be resolved against [appellant]." (Hernandez v. California Hospital Medical Center (2000) 78 Cal.App.4t

2025(Berger v. Godden (1985) 163 Cal.App.3d 1113 , 1119–1120 [an appellant’s failure “to articulate any pertinent or intelligible legal argument in an opening brief may, in the discretion of the court, be deemed an abandonment of the appeal justifying dismissal”].) A “cardinal rule of appellate review” is that a trial court’s order “is presumed correct and prejudicial error must be affirmatively shown.” (Foust v. San Jose Construction Co., Inc. (2011) 198 Cal.App.4th 181, 187 .) “ ‘A necessary corollary to this rule is that if the record is inadequate for meaningful review, the appellant defaults

2025(Denham v. Superior Court (1970) 2 Cal.3d 557 , 564 . . . .) ‘In the absence of a contrary showing in the record, all presumptions in 3 favor of the trial court’s action will be made by the appellate court. “[I]f any matters could have been presented to the court below which would have authorized the order complained of, it will be presumed that such matters were presented.” ’ ” (Foust v. San Jose Construction Co., Inc. (2011) 198 Cal.App.4th 181, 187 .) “An appellant has the burden to overcome the presumption of correctness and show prejudicial error.” (Silva v. See’s Candy Shops, Inc. (2016)

2025(See Jameson, supra, at p. 609 .) “ ‘ “A necessary corollary to this rule is that if the record is inadequate for meaningful review, the appellant defaults and the decision of the trial court should be affirmed.” ’ [Citation.] ‘Consequently, [the appellant] has the burden of providing an adequate record. [Citation.] Failure to provide an adequate record on an issue requires that the issue be resolved against [the appellant].’ [Citation.]” (Jameson, supra, 5 Cal.5th at p. 609 , fn. omitted; see also Maria P. v. Riles (1987) 43 Cal.3d 1281 , 1295–1296 [“Because they failed to furnish an adequate

2013(Yield Dynamics, Inc. v. TEA Systems Corp. (2007) 154 Cal.App.4th 547, 556-557 .) A necessary corollary to this rule is that if the record is inadequate for meaningful review, the appellant defaults and the decision of 14. the trial court should be affirmed.

2025“It is the duty of counsel to refer the reviewing court to the portion of the record which supports appellant's contentions on appeal. [Citation.] If no citation ‘is furnished on a particular point, the court may treat it as waived.’ [Citation.] We find this is an appropriate case in which to apply the waiver rule.” (Guthrey v. State of California (1998) 63 Cal.App.4th 1108 , 1115; see also In re S.C. (2006) 138 Cal.App.4th 396 , 406-407 [“When an appellant’s brief makes no reference to the pages of the record where a point can be found, an appellate court need not search through the record in

2015We would not reverse absent a showing that “no judge could reasonably have made the order, considering all of the evidence viewed most favorably in support of the order.” (In re Marriage of Winternitz (2015) 235 Cal.App.4th 644, 657 .) 4 favor of the trial court’s action will be made by the appellate court. ‘[I]f any matters could have been presented to the court below which would have authorized the order complained of, it will be presumed that such matters were presented.’ ” (Bennett v. McCall (1993) 19 Cal.App.4th 122, 127 .) “ ‘A necessary corollary to this rule is that if the record is in