CourtListener opinion 11239633

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In the
 Court of Appeals
Second Appellate District of Texas
 at Fort Worth
 ___________________________
 No. 02-25-00252-CV
 ___________________________

 GREGORY WAYNE COON, Appellant

 V.

 VICTORIA JACOBS THOMAS, Appellee

 On Appeal from the 233rd District Court
 Tarrant County, Texas
 Trial Court No. 233-694810-21

Before Sudderth, C.J.; Birdwell and Wallach, JJ.
 Memorandum Opinion by Justice Birdwell
 MEMORANDUM OPINION

 I. Introduction

 This dispute between Appellant Gregory Wayne Coon and Appellee Victoria

Jacobs Thomas arises from the division of Thomas's retirement benefits in their 1996

divorce. In 2021, the trial court entered a judgment nunc pro tunc on that division. See

Coon v. Coon (Coon I), No. 02-21-00381-CV, 2022 WL 7232163, at *1 (Tex. App.—

Fort Worth Oct. 13, 2022, no pet.) (mem. op.); Coon v. Coon (Coon II), No. 02-23-

00210-CV, 2024 WL 3896084, at *1 (Tex. App.—Fort Worth Aug. 22, 2024, no pet.)

(mem. op.). The crux of this appeal (and its predecessors) is whether the judgment

nunc pro tunc repaired clerical errors or impermissibly attempted to correct judicial

errors after plenary power had expired.

 In the instant appeal,1 Coon complains in his first two issues that the trial court

erred by making substantive rather than clerical changes to the 1996 judgment; in his

third issue, he contends that the trial court erred by refusing to enforce the original

1996 decree; and in his final issue, he argues that the trial court erred by awarding

attorney's fees to Thomas. Because the record reflects that the changes were clerical,

we overrule Coon's first three issues. And because the trial court had at least one

statutory basis upon which to award attorney's fees to Thomas, we also overrule his

fourth issue and affirm the trial court's judgment.

 1
 Coon raised the same issues in his earlier appeals, but we did not reach them
for procedural reasons.

 2
 II. Background

 In the parties' April 17, 1996 final decree of divorce, the trial court awarded to

Coon 40% of Thomas's retirement benefits "existing by reason of [her] past, present,

or future employment." However, after a remand by this court for clarification under

Baker v. Bizzle, 687 S.W.3d 285, 293 (Tex. 2024),2 the parties agreed and the trial court

ordered that before the decree's signing, the rendition had occurred in a letter ruling

on February 15, 1996.

 The February 15, 1996 letter ruling granted the parties' divorce.3 The trial court

observed in the letter ruling that the case had been contested and that the parties had

submitted their issues to the trial court to decide. The trial court awarded to Thomas

"60% of her retirement benefits with the FDIC or elsewhere" and awarded to Coon

"40% of such retirement benefits by Qualified Domestic Relations Order

[(QDRO)]."4 The letter ruling did not contain the "past, present, or future

 2
 In Baker, the supreme court clarified the requirements for a letter ruling to be
considered a rendition. 687 S.W.3d at 292–93. Citing Baker, we remanded this case to
the trial court in Coon II because the record before us did not show whether the
February 15, 1996 letter ruling met Baker's requirements. 2024 WL 3896084, at *1 &
n.3.
 3
 Among other things, the letter ruling also established the parties' possession of
the children, ordered Coon to pay monthly child support, and ordered the sale of the
parties' residence.
 4
 A QDRO is a "species of post-divorce enforcement" order that permits
payment to an alternate payee of a pension, retirement plan, or other employee
benefits. Pelloat v. McKay, No. 13-15-00456-CV, 2017 WL 2375762, at *3 (Tex. App.—
Corpus Christi–Edinburg June 1, 2017, no pet.) (mem. op.) (stating that a QDRO is a

 3
 employment" language included in the decree two months later. The trial court's

August 16, 1996 QDROs dividing Thomas's FDIC 401k Savings Plan and her Thrift

Savings Plan stated that the date of divorce was February 15, 1996; the QDROs

awarded to Coon 40% of Thomas's vested plans as of that date. Neither party

appealed either the decree or the QDROs.

 In 2021, Coon filed a petition for enforcement of the property division based

on the decree's language. See Coon I, 2022 WL 7232163, at *1. Both parties moved for

summary judgment, but Thomas also filed a motion for judgment nunc pro tunc or

alternative request for clarification, contending that the decree contained a clerical

error in its reference to "future employment" when the rendition did not contain that

language. See id. at *2 (summarizing the parties' motions).

 The trial court entered a judgment nunc pro tunc, deleting the words "past,

present, or future employment," and replacing them with "employment as of

February 15, 1996." See id. at *2–3. The trial court also added Thomas's FERS pension

to the list of divisible plans. As set out below, illustrated by strike-out of the trial

final appealable order); see Woodward v. Woodward, No. 14-18-00039-CV, 2019 WL
3943020, at *2 n.1 (Tex. App.—Houston [14th Dist.] Aug. 20, 2019, no pet.) (mem.
op.) (citing Tex. Fam. Code Ann. § 9.101). A pension plan that receives a valid
QDRO must pay the plan benefits to the designated alternate payee. Dalton v. Dalton,
551 S.W.3d 126, 137–38 (Tex. 2018). Concurrent with its power to clarify and to
enforce a decree's property division, a trial court also has continuing, exclusive
jurisdiction to render an enforceable QDRO permitting payment of a pension,
retirement plan, or other employee benefits divisible under the law of this state or of
the United States to an alternate payee. Pelloat, 2017 WL 2375762, at *3.

 4
 court's deletions and italicization of the trial court's additions, the trial court thus

modified the 1996 divorce decree's provisions:

 [Thomas] is awarded the following as [her] sole and separate
 property, and . . . [Coon] is divested of all right, title, interest, and claim
 in and to such property:

 (d) Sixty percent of any and all sums, whether matured or
 unmatured, accrued or unaccrued, vested or otherwise, together
 with all increases thereof, the proceeds therefrom, and any other
 rights related to any profit-sharing plan, retirement plan, pension
 plan, employee stock option plan, employee savings plan, accrued
 unpaid bonuses, or other benefit program existing by reason of
 [Thomas's] past, present, or future employment as of February 15,
 1996, including specifically the following retirement benefits with
 FDIC:
 (1) Thrift Savings Plan; and
 (2) FDIC Savings Plan; and
 (3) FERS Pension[.]

 ....

 [Coon] is awarded the following as [his] sole and separate
 property, and [Thomas] is hereby divested of all right, title, interest, and
 claim in and to such property:

 (c) Forty percent of any and all sums, whether matured or
 unmatured, accrued or unaccrued, vested or otherwise, together
 with all increases thereof, the proceeds therefrom, and any other
 rights related to any profit-sharing plan, retirement plan, pension
 plan, employee stock option plan, employee savings plan, accrued
 unpaid bonuses, or other benefit program existing by reason of
 [Thomas's] past, present, or future employment as of February 15,
 1996, including specifically [her] following retirement benefits
 with FDIC:
 (1) Thrift Savings Plan; and
 (2) FDIC Savings Plan; and
 (3) FERS Pension

 5
 as more fully set forth in a Qualified Domestic Relations Order.
 The FERS Pension shall be divided pursuant to a Court Order Acceptable
 for Processing . . . .

The trial court also awarded to Thomas $15,392.50 in attorney's fees. See id. at *3.

 III. Discussion

 Because part of Coon's property-division argument relies upon his

characterization of Thomas's "conceding that she [did] not meet the burden of proof

necessary to prove [at the 1996 trial] which part of the retirement is her separate

property," we will briefly review marital property division before reaching his specific

issues.

A. Marital property

 Regarding future property, the Texas constitution provides that spouses may

partition between themselves property "then existing or to be acquired" but also that

"laws shall be passed more clearly defining the rights of the spouses, in relation to

separate and community property." Tex. Const. art. XVI, § 15 (emphasis added); see

Tex. Fam. Code Ann. § 2.501 (stating that "[e]ach spouse" has the duty to support the

other). We turn to the Family Code, which defines what property may be divided

upon the marriage's dissolution. See Tex. Fam. Code Ann. §§ 3.001–.003; see also id.

§ 1.003 (defining "[s]uit for dissolution of a marriage" as, among other things, a "suit

for divorce").

 A marriage's existence generally determines whether property is community:

"property, other than separate property, acquired by either spouse during marriage." Id.

 6
 § 3.002 (emphasis added); see also id. § 3.003 (explaining that there is a presumption

that property is community if possessed by either spouse "during or on dissolution"

of marriage). The trial court granted the parties' divorce here on February 15, 1996, in

its letter ruling. Accordingly, under the Family Code, any property acquired by the

parties after that date would not be community property—and thus should not have

been divided—because Coon and Thomas were no longer spouses. See id. §§ 3.002–

.003. But see Shanks v. Treadway, 110 S.W.3d 444, 449 (Tex. 2003) (explaining, as to an

unappealed decree, that the district court's erroneous application of law by awarding

to ex-wife some of ex-husband's separate property interest in his retirement benefits

"does not alter the decree's plain language"); 5 see also Pearson v. Fillingim, 332 S.W.3d

361, 363 (Tex. 2011) ("A judgment finalizing a divorce and dividing marital property

 5
 In Shanks, the decree awarded to the ex-wife a 25% interest in the ex-
husband's retirement benefits without limiting her interest post-divorce, and neither
party appealed. 110 S.W.3d at 445 (stating that ex-wife was awarded 25% "of the total
sum or sums paid or to be paid to [ex-husband] from such pension or retirement
plan" and that her interest was in "any and all sums received or paid to [ex-husband]
from such pension plan . . . if, as and when paid . . . to [him]"). Years later, the ex-
husband sought a QDRO calculating the value of her interest as of the date of divorce
and she countered by seeking a QDRO valuing her 25% share of his total benefits. Id.
The trial court entered the QDRO sought by the ex-husband, and our sister court
reversed the judgment, concluding that the QDRO impermissibly altered the original
decree's substantive division. Id. at 446. The supreme court agreed with this
interpretation because the decree was unambiguous, and it affirmed the intermediate
court's judgment. Id. at 446–48 ("Whether intentional or not, the court that entered
the decree failed to limit the community interest . . . and instead clearly gave [ex-wife]
a twenty-five percent interest in the total amount . . . to be paid to [ex-husband] under
the plan."). The issue here—divergence between rendition and decree and resolution
by nunc pro tunc—did not appear in Shanks.

 7
 bars relitigation of the property division, even if the decree incorrectly characterizes or

divides the property."). 6

 Here, the decree's original language regarding Thomas's "future" earnings

divested her of a share of her separate property based on post-divorce earnings. The

question before us is whether the trial court could repair the decree by using a

judgment nunc pro tunc based on the rendition letter, which did not contain the

problematic language that appeared in the decree but which also did not expressly set

out the date of rendition as a limit.

B. The nunc pro tunc issues

 Coon challenges the judgment nunc pro tunc in his first two issues and the trial

court's failure to enforce the decree in his third issue. We begin by reviewing the law

applicable to judgments nunc pro tunc and related case law before applying that law

to the facts and arguments before us.

 1. Nunc pro tunc

 Clerical mistakes in the record of any judgment may be corrected by the judge

in open court in a judgment nunc pro tunc "according to the truth or justice of the

 6
 In Pearson, 25 years after the parties' divorce was entered, the ex-husband
sought to reclassify an asset—mineral interests inherited from his parents—as his
separate property through a motion to clarify the decree and a separate declaratory-
judgment action. 332 S.W.3d at 362. The supreme court held that because the ex-
husband had failed to appear at the divorce trial, he had failed to rebut the
community-property presumption applied to that asset, and the original property
division was not subject to his collateral attack. Id. at 363–64 (holding that the trial
court lacked jurisdiction to alter the original divorce decree).

 8
 case . . . and thereafter the execution shall conform to the judgment as amended."

Tex. R. Civ. P. 316. A judgment nunc pro tunc under Rule 316 may clarify an original

judgment or correct a clerical error, but it may not substantively alter an original

judgment to correct a judicial error. U.S. Cap. Invs., LLC v. Shahbazi, No. 02-17-00199-

CV, 2018 WL 772761, at *4 (Tex. App.—Fort Worth Feb. 8, 2018, pet. denied) (mem.

op.).

 We have previously reviewed the distinction between clerical and judicial errors

in another divorce-related dispute, stating,

 "A clerical error is one that results from an inaccurate recording of the
 court's decision" such that "the signed judgment inaccurately reflects the
 true decision of the court." Andrews v. Koch, 702 S.W.2d 584, 585–86
 (Tex. 1986); In re S.D., No. 02-10-00221-CV, 2011 WL 3847440, at *3
 (Tex. App.—Fort Worth Aug. 31, 2011, no pet.) (mem. op.); see Tex.
 Dep't of Transp. v. A.P.I. Pipe & Supply, LLC, 397 S.W.3d 162, 167 (Tex.
 2013). A judicial error, in contrast, "stems from a legal or factual mistake
 that requires judicial reasoning to correct." In re J.S., No. 02-19-00231-
 CV, 2019 WL 5655254, at *3 (Tex. App.—Fort Worth Oct. 31, 2019,
 pet. denied) (mem. op.); see Escobar v. Escobar, 711 S.W.2d 230, 231 (Tex.
 1986) (clarifying that "a clerical error [is one] made in entering final
 judgment" while "a judicial error [is one] made in rendering a final
 judgment").

Keating v. Keating, No. 02-20-00271-CV, 2022 WL 187985, at *7 (Tex. App.—Fort

Worth Jan. 20, 2022, no pet.) (mem. op.). That is, a clerical error is a discrepancy

between the entry of a judgment in the record and the judgment that was actually

rendered by the court and that does not arise from judicial reasoning or

determination. Willow Vista Ests. Homeowners Ass'n, Inc. v. Haight, No. 02-12-00432-CV,

2013 WL 4506821, at *1 (Tex. App.—Fort Worth Aug. 22, 2013, no pet.) (mem. op.);

 9
 see Andrews, 702 S.W.2d at 586 ("When a prior judicial determination is evidenced, but

the signed judgment inaccurately reflects the true decision of the court, the error is

clerical and may be corrected.").

 An attempted nunc pro tunc judgment entered after the trial court loses plenary

power is void if it corrects judicial rather than clerical errors, but even a significant

alteration to the original judgment may be accomplished through a judgment nunc pro

tunc so long as it merely corrects a clerical error. Tex. Dep't of Transp., 397 S.W.3d at 167.

 When deciding whether a correction is of a judicial or a clerical error, we look

at the judgment actually rendered, not the judgment that should or might have been

rendered. Escobar, 711 S.W.2d at 231. A court cannot alter a written judgment that

precisely reflects an incorrect rendition.7 Id. at 232. Whether an error in a judgment is

judicial or clerical is a question of law. Id. But the pronouncement's terms are

questions of fact. Id. The judicial or clerical question becomes a question of law only

after the trial court factually determines whether it previously rendered judgment and

the judgment's contents. Id. To render a judgment nunc pro tunc, there must be some

 7
 Reducing a decision to final judgment has three phases: (1) rendition;
(2) signing; and (3) entry. Baker, 687 S.W.3d at 291. Rendition and signing are judicial
acts that can, but need not, occur at the same time. Id. Entry, on the other hand, is a
clerical act undertaken by the clerk of the court. Id. at 291–92. A judgment's
"rendition" is the judicial act by which the court settles and declares the decision of
the law upon the matters at issue. Id. at 292. Rendition requires a present act, either by
spoken word or signed memorandum, that decides the issues on which the ruling is
made. Id. An error in rendition is always judicial error, which may not be corrected by
a judgment nunc pro tunc. In re Marriage of Martz, No. 09-21-00048-CV, 2022 WL
2251731, at *4 (Tex. App.—Beaumont June 23, 2022, pet. denied) (mem. op.).

 10
 evidence that the judgment the trial court actually rendered is not correctly

represented in the judgment signed and entered of record. Martz, 2022 WL 2251731,

at *4.

 Additionally, trial courts have no authority to enter a QDRO altering the

substantive property-division terms. See Dalton, 551 S.W.3d at 140. 8 The court can

enter a "clarifying order" to enforce compliance with an insufficiently specific division

by more precisely specifying the manner of carrying out a previously ordered property

division, but it may not amend, modify, alter, or change the property division. Id. If a

judgment is ambiguous—that is, subject to more than one reasonable interpretation—

courts should adopt the construction that correctly applies the law. Shanks, 110

S.W.3d at 447.

 2. The parties' arguments

 In his first two issues, Coon argues that the deletion of the "past, present, or

future employment" language and the addition of the rendition date were errors

outside of the trial court's plenary power when the rendition contained no limitation

as to the time during which the divided retirement benefits were to be accrued and no

 In Dalton, the trial court entered multiple QDROs, each time allocating
 8

additional interests to the ex-wife in the ex-husband's retirement accounts in response
to his failure to pay support obligations entered in an out-of-state agreement that had
been incorporated into the Texas divorce decree. 551 S.W.3d at 130–33. The supreme
court reversed because "no Texas procedure or remedy allowed the court to assign
[ex-wife] more interests in [ex-husband's] retirement accounts than were assigned in
the final divorce decree." Id. at 137. The 1996 QDROs here do not purport to make
such a division.

 11
 limitation of the divided benefits to the "community portion" of Thomas's retirement

benefits accrued before the date of divorce. He complains that adding the date

limitation that was not in the original rendition "changes completely the breadth of

the award stated in the rendition by severely narrowing it" and that the trial court

erred by refusing to enforce the decree's unambiguous language.

 Thomas responds that the decree did not match the rendition, which did not

explicitly award to Coon any of her federal retirement benefits accruing after the date

of divorce. She argues that the trial court's contemporaneous orders—the QDROs—

divided some of her federal retirement benefits as of the date of rendition and

clarified the trial court's intent to not award to Coon any of her benefits accruing after

divorce.

 3. Application

 The three-page February 15, 1996 rendition recited that the parties were

divorced as of that date, that the case was contested, and that Thomas was "awarded

60% of her retirement benefits with the FDIC or elsewhere and [Coon was] awarded 40%

of such retirement benefits by Qualified Domestic Relations Order." [Emphases added.] When

the decree failed to match this rendition, a clerical error occurred. That is, as reflected

in this record, the decree added language beyond what the rendition provided.

 We note that some of the decree's additional language, which the trial court did

not strike in the judgment nunc pro tunc, could be reasonably construed as mere

clarification of the "retirement benefits . . . elsewhere" referenced in the rendition:

 12
 any and all sums, whether matured or unmatured, accrued or unaccrued,
 vested or otherwise, together with all increases thereof, the proceeds
 therefrom, and any other rights related to any profit-sharing plan,
 retirement plan, pension plan, employee stock option plan, employee
 savings plan, accrued unpaid bonuses, or other benefit program existing
 by reason of [Thomas's] . . . employment[.]

These are all types of benefits provided by reason of employment for retirement

purposes, and the decree specifically included the Thrift Savings Plan and the FDIC

Savings Plan—the "retirement benefits with the FDIC or elsewhere" that were

addressed in the subsequently entered QDROs. Further, the allocation to Coon in the

decree added, "as more fully set forth in a [QDRO]," paralleling the rendition

language.

 The August 16, 1996 QDROs, which were specifically identified in both the

rendition and the decree, awarded to Coon "40% of the vested FDIC 401K Savings

Plan account of [Thomas], Participant as of February 15, 1996," and "40% of the vested

Thrift Savings Plan account of [Thomas], Participant as of February 15, 1996."

[Emphases added.]

 The rendition did not identify any award based on Thomas's "future

employment," and the QDROs entered not long after the rendition and decree

clarified the distribution "as of February 15, 1996," i.e., the date of rendition.

Accordingly, the trial court could have reasonably found that the temporal reference

to Thomas's future employment was a clerical error subject to correction through the

 13
 judgment nunc pro tunc to reflect Thomas's employment as of the February 15, 1996

rendition.

 To support his position, Coon refers us to the following cases: Stirling v. Stirling,

No. 02-10-00329-CV, 2011 WL 3211242, at *1 (Tex. App.—Fort Worth July 28,

2011, no pet.) (mem. op.); Reiss v. Reiss, 118 S.W.3d 439, 440–42 (Tex. 2003); Wagner v.

Davis, No. 02-19-00249-CV, 2020 WL 241381, at *3 (Tex. App.—Fort Worth Jan. 16,

2020, no pet.) (mem. op.); and In re Marriage of Russell, 556 S.W.3d 451, 459–60 (Tex.

App.—Houston [14th Dist.] 2018, no pet.). These cases were argued at the parties'

2021 hearing, and Thomas distinguishes each, as she did at that hearing, pointing out

that the first three were not nunc pro tunc cases and the last did not involve a

separate rendition. We will address each in turn.

 In Stirling, the decree used the same "past, present, or future employment"

language as the instant decree to divide two of the ex-husband's retirement plans.

2011 WL 3211242, at *1. The ex-wife subsequently discovered another of his

retirement plans and filed a petition for post-divorce division of community property

but not—as here—a motion for judgment nunc pro tunc. Id. Although the trial court

granted her petition to divide the additional retirement benefits, we reversed,

concluding that the parties' agreed divorce decree had unambiguously divided the

entire community estate. Id. at *2. In contrast, in the instant case, the parties' decree

 14
 was not agreed, 9 and it diverged from the rendition. As argued by Thomas, Stirling is

distinguishable.

 In Reiss, the trial court awarded to the ex-wife 50% of the ex-husband's

retirement benefits in a decree that specified that "if and when [ex-husband] retires

and/or receives a pension from Goodyear[], or for any other reason becomes entitled

to receive retirement or pension benefits from Goodyear[], then, and in such event,

[ex-wife] shall receive fifty percent (50%) of such retirement or pension benefit to which [ex-

husband] is entitled to receive from Goodyear[]." 118 S.W.3d at 440 (emphasis added). As

here, neither party appealed. Id. at 440, 442.

 Years later, when the ex-husband retired, the ex-wife moved for a QDRO to

enforce the division, including any sums accrued after the divorce, and the trial court

granted it. Id. at 440–41. The supreme court held that in entering the original decree,

the trial court "in effect mistakenly classif[ied] all of the benefits [the ex-husband] was

entitled to receive under the plan as community property and divid[ed] them as such."

Id. at 441. But because it was unambiguous, although the decree's effect was to divest

 9
 Although Coon contends that paragraph 3 of the affidavit he filed in support
of his summary-judgment motion supports his appellate position, this portion of his
affidavit is not "clear, positive and direct . . . and free from contradictions and
inconsistencies." See Tex. R. Civ. P. 166a(c). That is, in paragraph 3, Coon asserted
both that they "had a fully contested trial[.] . . . The Court's ruling was that [Thomas]
would take 60% of all of accumulated our [sic] retirement funds, and [Coon] would
receive only 40%," but also, "[Thomas] and her attorney . . . agreed to have the Court
just split the retirement 60/40." [Emphases added.] We infer that the trial court took
these inconsistencies into account when it denied Coon's summary-judgment motion.
See Coon I, 2022 WL 7232163, at *2.

 15
 him of his separate property, "that does not alter the decree's plain language." Id. at

441–42. The decree's language "unequivocally award[ed]" to the ex-wife half of his

"total retirement benefits under the plan, regardless of when they accrued." Id. at 442.

The QDRO was consistent with the unappealed decree's unambiguous property

division. Id. Here, in contrast, it is the decree that does not match the rendition or the

QDROs. Thus, Reiss is also distinguishable from the instant case.

 In Wagner, the trial court granted an order on the ex-wife's motion to clarify the

parties' agreed divorce decree in which the ex-husband was awarded 50% of the

proceeds from the sale of the marital residence, and the ex-wife was ordered to pay

him 50% of the equity as of the sale date. 2020 WL 241381, at *1. The trial court

entered an order clarifying that the ex-husband's share was 50% of the community

value on the date of the divorce. Id. at *2. We reversed because the agreed decree

expressly set out when and how to value his interest—at the time of sale—and thus

the trial court had erred by finding ambiguity and rewriting the parties' contract. Id. at

*4. Here, in contrast, there was no agreement between the parties—it was a contested

divorce—and unlike the instant case, Wagner did not involve a divergence between the

terms of the rendition and decree.

 Finally, in Russell, the parties signed a mediated settlement agreement (MSA)

that allocated $201,000 of the ex-husband's 401k to the ex-wife as of September 28,

2015, but this item was not discussed at the prove-up hearing, and three days later, the

trial court signed and entered the decree, which did not include that award. 556

 16
 S.W.3d at 453. Several months later, after plenary power had expired, the ex-wife

sought a judgment nunc pro tunc, and the trial court granted it. Id. at 453–54.

 Our sister court concluded that the judgment nunc pro tunc was void because

there was no evidence that the trial court had rendered a judgment different from the

final divorce decree—nothing in the decree, to which the parties had agreed in form

and substance, stated that it was approving or incorporating the MSA, and the decree

explicitly stated that it would control to the extent any conflict existed between it and

the MSA. Id. at 458–61. The judgment nunc pro tunc changed the parties' substantive

rights under the decree and corrected judicial, not clerical, errors. Id. at 460–61. In

contrast, here, the rendition (judicial action) occurred before the decree's entry

(clerical action).

 Nothing in the cases Coon relies upon contradicts our analysis above.

Accordingly, because the trial court corrected a clerical error, we overrule Coon's first

two issues. And because the correction deleted the inappropriate future language,

which is what Coon sought to enforce, the trial court did not err by denying his

motion for enforcement. We overrule his third issue.

C. Attorney's fees

 In his final issue, Coon argues that the trial court erred by awarding to Thomas

her attorney's fees incurred in making her request for the judgment nunc pro tunc,

asserting that there is no statutory or contractual authorization to support the award.

Thomas responds that the trial court did not err because the judgment nunc pro tunc

 17
 proceeding was to correct an underlying divorce decree, see Tex. Fam. Code Ann.

§ 6.708, and that attorney's fees are allowed on a motion for enforcement, which is

what Coon filed, or on a motion for clarification, which Thomas incorporated into

her motion, because both actions are included in the part of the Family Code

addressing post-decree enforcement, see id. §§ 9.006 (enforcement), 9.008

(clarification), 9.014 ("The [trial] court may award reasonable and necessary attorney's

fees . . . in a proceeding under this subchapter.").10

 A trial court may award reasonable attorney's fees in appropriate family-law

proceedings, including a proceeding to clarify and enforce a property division, and we

review such an award for an abuse of discretion. Garcia v. Ranft-Garcia, No. 04-22-

00415-CV, 2024 WL 1184458, at *4 (Tex. App.—San Antonio Mar. 20, 2024, no pet.)

(mem. op.); see E.R. v. B.R., No. 02-16-00367-CV, 2017 WL 4172065, at *3 (Tex.

App.—Fort Worth Sept. 21, 2017, no pet.) (per curiam) (mem. op.) (citing Family

Code Section 6.708(c) as one of several potential statutory bases to support an

attorney's-fee award); see also Fowler v. Fowler, No. 2-07-274-CV, 2008 WL 2330987, at

*2 (Tex. App.—Fort Worth June 5, 2008, no pet.) (mem. op.) (reciting abuse-of-

discretion standard of review for rulings on motions for enforcement, for clarification,

and for payment of attorney's fees).

 To determine whether a trial court has abused its discretion, we must decide

whether it acted without reference to any guiding rules or principles, i.e., whether its

 Coon does not challenge the award's reasonableness or necessity.
 10

 18
 act was arbitrary or unreasonable. Fowler, 2008 WL 2339087, at *2 (citing Downer v.

Aquamarine Operators, Inc., 701 S.W.2d 238, 241–42 (Tex. 1985)). When, as here, the

trial court does not set out the statutory basis for the attorney's-fee award in its order,

it acts within its discretion if there is a valid legal basis for its actions. Garcia, 2024 WL

1184458, at *4–5 ("[W]e cannot hold [that] the trial court abused its discretion by

awarding fees to [ex-wife] for prosecuting her enforcement action under Chapter 9 of

the Texas Family Code.").

 Regardless of the titles of the parties' various motions, see Brumley v. McDuff, 616

S.W.3d 826, 833 (Tex. 2021) (requiring us to examine substance rather than form),

their dispute centered on clarifying and enforcing the property division arising from

their divorce. Because of this, as pointed out by Thomas, the trial court had at least

one statutory basis upon which to award attorney's fees to her. See Garcia, 2024 WL

1184458, at *4; see also Tex. Fam. Code Ann. §§ 9.006, .008, .014. Accordingly, we

cannot say that the trial court abused its discretion by awarding attorney's fees to

Thomas, and we overrule Coon's final issue.

 IV. Conclusion

 Having overruled all of Coon's issues, we affirm the trial court's judgment.

 /s/ Wade Birdwell

 Wade Birdwell
 Justice

Delivered: January 8, 2026

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