Fourth Court of Appeals
San Antonio, Texas
MEMORANDUM OPINION
No. 04-12-00872-CR
IN RE Christopher CRUMEDY
Original Mandamus Proceeding 1
PER CURIAM
Sitting: Karen Angelini, Justice
Marialyn Barnard, Justice
Luz Elena D. Chapa, Justice
Delivered and Filed: January 23, 2013
PETITION FOR WRIT OF MANDAMUS DENIED
On December 31, 2012, Relator Christopher Crumedy filed a petition for writ of
mandamus, complaining of the trial court’s failure to rule on his pro se motion for speedy trial.
However, counsel has been appointed to represent relator in the criminal proceeding pending in
the trial court for which he is currently confined. A criminal defendant is not entitled to hybrid
representation. See Robinson v. State, 240 S.W.3d 919, 922 (Tex. Crim. App. 2007); Patrick v.
State, 906 S.W.2d 481, 498 (Tex. Crim. App. 1995). A trial court has no legal duty to rule on
pro se motions or petitions filed with regard to a criminal proceeding in which the defendant is
represented by counsel. See Robinson, 240 S.W.3d at 922. Consequently, the trial court did not
abuse its discretion by declining to rule on relator’s pro se motion filed in the criminal
1
This proceeding arises out of Cause No. 2012-CR-0263, styled State of Texas v. Christopher Crumedy, pending in
the 175th Judicial District Court, Bexar County, Texas, the Honorable Mary D. Roman presiding.
04-12-00872-CR
proceeding pending in the trial court. Accordingly, the petition for writ of mandamus is denied.
TEX. R. APP. P. 52.8(a).
PER CURIAM
DO NOT PUBLISH
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