Can I represent myself in Texas family court if I also have a lawyer?

This question has been addressed in 2 Texas court opinions:

In re Juan Pardo

COA13 — January 30, 2026

In this mandamus proceeding, Relator Juan Pardo sought to vacate trial court orders for his arrest via ex parte writs of attachment. Although Pardo was represented by two attorneys of record, he filed the petition pro se. The Real Party in Interest moved to dismiss, arguing that Texas law prohibits 'hybrid representation.' The Thirteenth Court of Appeals agreed, holding that a party in a civil case cannot represent themselves while concurrently being represented by counsel. Because the petition was procedurally improper, the court dismissed it without prejudice and lifted a previously granted emergency stay, effectively exposing the Relator to the trial court's enforcement orders.

Litigation Takeaway

“Pro se filings made by a party who is still represented by counsel of record are considered a procedural nullity. Clients must formalize the termination of their legal representation before attempting to file original proceedings independently, or they risk immediate dismissal and the loss of emergency stays.”

K.C. v. T.C.-J.

COA07 — February 6, 2026

In a parental termination case, an indigent mother (K.C.) appealed the termination of her rights and subsequently requested to discharge her court-appointed lawyer to represent herself (pro se). The Amarillo Court of Appeals analyzed this request under the "quasi-criminal" nature of termination proceedings, which requires that any waiver of the right to counsel be knowing, intelligent, and competent. Because the existing record contained no evidence of the mother's understanding of the "dangers and disadvantages" of self-representation, the court held that an evidentiary hearing was mandatory. The court abated the appeal and remanded the case to the trial court to determine the mother's competence and the voluntariness of her waiver.

Litigation Takeaway

“In high-stakes family law matters like parental termination, a parent cannot simply choose to represent themselves on appeal without a formal 'competency' inquiry. To prevent significant delays and the pausing of an appeal, trial counsel must ensure the record includes specific judicial findings that the client understands the risks and complexities of proceeding pro se.”