AFFIRMED and Opinion Filed March 2, 2021 

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In The 

### Court of Appeals Fifth District of Texas at Dallas No. 05-19-01470-CV MACARTHUR DAVIS, Appellant V. AMERICAN EXPRESS NAT IONAL BANK, Appellee On Appeal from the 44th Judicial District Court Dallas County, Texas Trial Court Cause No. DC-19-14257 MEMORANDUM OPINION Before Justices Schenck, Smith, and Garcia Opinion by Justice Smith Appellee American Express National Bank sued pro se appellant M acArthur Davis for the balance due on a business credit card. After Dav is failed to answer, American Express filed a motion for default judgment. The tria l court granted the default judgment and awarded Am erican Express $29,983.18 and co urt costs. MacArthur argues on appeal that he is entitled to “qualified im munity” and cannot be held personally liable for th e debts of a limited liability company. Davis has failed to provide any substantive analysis with citat ion to the record or relevant legal authorities in support of his arguments there by waiving his issues–2– on appeal. See T EX
. R. A PP
. P. 38.1(h); see also PopCap Games, Inc. v. MumboJumbo, LLC , 350 S.W.3d 699, 722 (Tex. App. —Dallas 2011, pet. denied). To the extent we liberally const rue his arguments, we conclude they are without merit and affirm the trial court’s judgment. Because the under lying facts are wellknown to the parties, we include only those necessary for dispo sition of this appeal.
See T EX
. R. A PP
. P. 47.4. Inadequate Briefing We begin by addressing the briefing deficiencies in Davis’s pro se brief. A pro se litigant is held to the same standards as a licensed att orney and, therefore, must comply with the applicable rules of appellate procedure, i ncluding rule 38.1. See Wash. v. Bank of N.Y. , 362 S.W.3d 853, 854 (Tex. A pp.—Dallas 2012, no pet.). To do otherwise would give a pro se litigant an unfair advantag e over a litigant who is represented by counsel. Id

. Davis’s brief fails to comply with rule 38.1 in several ways. Notably, he fails to include a single citation to the appellate record. See T EX
. R. A PP
. P. 38.1(g). Further, he has failed to make a clear, concise argument with c itation to relevant authorities. Id . 38.1( i). Instead, he cites four federal cases from other jurisdictions and two from federal courts in Texas, which are not controlling authority. See In re Fairway Methanol LLC , 515 S.W.3d 480, 489 (Tex. A pp.—Houston [14th Dist.] 2017, orig. proceeding). We provided Davis with notice of his briefing deficiencies and allowed the opportunity to f ile an amended brief. He filed an amended brief;–3– however, he still failed to comply with rule 38.1. Despite the se deficiencies, where possible we will liberally construe and address the arguments s et forth in Davis’s brief. See T EX
. R. A PP
. P. 38.9.
Discussion Davis first argues he is entitled to “qualified immunity” agai nst American Express’s cause of action. He c ites no relevant, legal basis f or his proposition. Instead, he cites to cases related to the federal fair-debt col lection statute and to qualified immunity for governmental actors. 1 Neither is applicable here. To the extent Davis attempts to challenge the merits of the de fault judgment, his arguments are without merit. He contends that as a general rule, a business owner cannot be held liable for the debts of a limited liability comp any. See T EX
. B US

. O RG

. C ODE A NN . § 101.114 (“Except as and to the extent the company agreement specifically provides otherwise, a member or manager is not lia ble for a debt, obligation, or liability of a li mited liability company, includ ing a debt, obligation, or liability under a judgmen t, decree, or order of a court.”). Ho wever, there is nothing

1 Diaz v. Kubler Corp ., 785 F.3d 1326 (9th Cir. 2015) (considering whether debt coll ector violated provisions of federal Fair Deb t Collections Practices Act); Anarion Invs. LLC v. Carrington Mortg. Servs., LLC , 794 F.3d 568 (6th Cir. 2015) (analyzing the meaning of “perso n” under FDCPA); Gillie v. Law Offices of Eric A. Jones , LLC, 785 F.3d 1091 (6th Cir. 2015) (considering misleading an d deceptive debt collection efforts by attorneys under FDCPA), judgment vacated by Jones v. Gillie , 136 S.Ct. 2446 (2016); Horton v. M&T Bank , No. 4:13-CV-525-A, 2013 WL 6172145 (N.D. Tex. Nov. 22, 2013) (discussing consumer claim under FDCPA); Appleberry v. Fort Worth Indep. Sch. Dist ., No. 4:12-CV-235-A, 2012 WL 5076039 (N.D. Tex. Oct. 17, 2012) (concluding , in part, individual supervisor s entitled to dismissal from ADA claims because statute did not impose such individual liability); Andrade v. Chojnacki , 65 F. Supp. 2d 431 (W.D. Tex. 1999) (discussing qualified immunity for government offici als regarding claims involving Branch Davidians).–4– in the record indicating Amazi ng Performance, the business at i ssue, is a limited liability company. The record shows Davis applied for, obtained, and used a credi t card. The card member agreement defined “You” and “Your” to mean the “Bas ic Card member and the Company” and that “You agree, jointly and severa lly to be bound by the terms of the Agreement.” Davis failed to pay the amount due on the account. When Davis failed to answer, he admitted both the truth of the facts set out in the petition and his liability on any cause of action properly alle ged by those facts. Paradigm Oil, Inc. v. Retamco Operating, Inc ., 372 S.W.3d 177, 183 (Tex. 2012) (non-answering party in a no-answer default judgment is said to have admitted both truth of facts set out in the petition and defendant’s liabilit y on any cause of action properly alleged by those facts) . Accordingly, the record supp orts the trial court’s judgment.
Conclusion We affirm the trial court’s jud gment in favor of American Expr ess.

191470F.P05 /Craig Smith/ CRAIG SMITH JUSTICE–5– 

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Court of Appeals Fifth District of Texas at Dallas JUDGMENT MACARTHUR DAVIS, Appellant
No. 05-19-01470-CV V.
AMERICAN EXPRESS NATIONAL BANK, Appellee On Appeal from the 44th Judicial District Court, Dallas County, Texas Trial Court Cause No. DC-19-14257. Opinion delivered by Justice Smith. Justices Schenck and Garcia participating.
In accordance with this Court’ s opinion of this date, the judg ment of the trial court is AFFIRMED

. It is ORDERED that appellee AMERICAN EXPRESS NATIONAL BANK recover its costs of this appeal from appellant MACARTHUR DAVIS

. Judgment entered March 2, 2021.