in Re Joshua Coca, Relator

MEMORANDUM OPINION
No. 04-11-00265-CR
IN RE Joshua COCA
Original Mandamus Proceeding 1
PER CURIAM
Sitting: Sandee Bryan Marion, Justice
Rebecca Simmons, Justice
Marialyn Barnard, Justice
Delivered and Filed: May 11, 2011
PETITION FOR WRIT OF MANDAMUS DENIED
On April 7, 2011, relator filed a petition for writ of mandamus, complaining of the trial
court’s failure to rule on his pro se motion to reduce bond. 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
1
This proceeding arises out of Cause No. 2009-CR-9772, styled State of Texas v. Joshua Coca, pending in the 144th
Judicial District Court, Bexar County, Texas, the Honorable Angus McGinty presiding.
04-11-00265-CR
declining to rule on relator’s pro se motion 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DO NOT PUBLISH
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