MEMORANDUM OPINION
No. 04-12-00381-CR
IN RE Vicente REYES
Original Mandamus Proceeding 1
PER CURIAM
Sitting: Phylis J. Speedlin, Justice
Rebecca Simmons, Justice
Marialyn Barnard, Justice
Delivered and Filed: July 11, 2012
PETITION FOR WRIT OF MANDAMUS DENIED
On June 22, 20122, Relator Vicente Reyes filed a petition for writ of mandamus,
complaining of the trial court’s failure to rule on a pro se Judicial Notice request. 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 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 request filed in the criminal proceeding
1
This proceeding arises out of Cause No. 2006CR6988, styled State of Texas v. Vicente Reyes, Jr., pending in the
290th Judicial District Court, Bexar County, Texas, the Honorable Melisa Skinner presiding.
04-12-00381-CR
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DO NOT PUBLISH
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