MEMORANDUM OPINION
No. 04-11-00472-CR
IN RE Stephen RICHARDSON
Original Mandamus Proceeding 1
PER CURIAM
Sitting: Catherine Stone, Chief Justice
Karen Angelini, Justice
Marialyn Barnard, Justice
Delivered and Filed: July 27, 2011
PETITION FOR WRIT OF MANDAMUS DENIED
On July 7, 2011, relator Stephen Richardson filed a petition for writ of mandamus,
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
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
1
This proceeding arises out of Cause No. 2010-CR-10629, styled State of Texas v. Stephen Richardson, pending in
the 399th Judicial District Court, Bexar County, Texas, the Honorable Juanita A. Vasquez-Gardner presiding.
04-11-00472-CR
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 is denied. TEX. R.
APP. P. 52.8(a).
PER CURIAM
DO NOT PUBLISH
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