MEMORANDUM OPINION
No. 04-12-00322-CR
IN RE Erica Dawn HAYWOOD
Original Mandamus Proceeding 1
PER CURIAM
Sitting: Sandee Bryan Marion, Justice
Phylis J. Speedlin, Justice
Steven C. Hilbig, Justice
Delivered and Filed: June 13, 2012
PETITION FOR WRIT OF MANDAMUS AND MOTION FOR EMERGENCY
RELIEF ARE DENIED
On May 24, 2012, Relator Erica Dawn Haywood filed a petition for writ of mandamus
and motion for emergency relief, complaining of the trial court’s failure to rule on various pro se
motions. However, counsel has been appointed to represent Relator in the criminal proceeding
pending in the trial court for which she 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
1
This proceeding arises out of Cause No. 2011CR4672, styled State of Texas v. Erica Dawn Haywood, pending in
the 399th Judicial District Court, Bexar County, Texas, the Honorable Juanita A. Vasquez-Gardner presiding.
04-12-00322-CR
court did not abuse its discretion by declining to rule on Relator’s pro se motions filed in the
criminal proceeding pending in the trial court. Accordingly, the petition for writ of mandamus
and motion for emergency relief are denied. TEX. R. APP. P. 52.8(a).
PER CURIAM
DO NOT PUBLISH
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