in Re Courtney Lee, 02-16-00375-CV

Courtney Lee filed a petition for writs of mandamus and prohibition seeking reinstatement of bond and a stay of criminal proceedings, arguing the trial court violated Tex. Code Crim. Proc. art. 46B.004(d) by failing to stay proceedings pending a competency determination.
Lee claimed the court declared her bond insufficient and increased it without first staying proceedings after evidence of incompetency arose.
The State informed the appellate court that the competency issue had been resolved by agreement, Lee pled guilty under a plea bargain, adjudication was deferred, and she was placed on ten years’ community supervision.
The State suggested the petition was now moot because the competency question and charges had been resolved.
Lee conceded the case was temporarily resolved but argued the issue was capable of repetition yet would evade review, so the court should rule on the mandamus petition.
The court examined mootness doctrine and the narrow "capable of repetition but evading review" exception and concluded Lee could not show a reasonable expectation she'd face the same action again; therefore relief would be useless and the petition was dismissed as moot.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether mandamus is moot after competency resolved and charges disposed	Lee: Not moot; still seeks ruling and exception applies	State: Moot — competency resolved and plea disposes charges	Moot; petition dismissed as relief would be useless
Whether the "capable of repetition but evading review" exception saves the petition	Lee: Future violation/adjudication could raise same competency/stay issue	State: Speculative; remote chain of events unlikely	Exception not satisfied; no reasonable expectation of repetition

Holcombe v. Fowler, 9 S.W.2d 1028 (Tex. 1928) (writ of mandamus will not issue if it would be useless)
Dow Chem. Co. v. Garcia, 909 S.W.2d 503 (Tex. 1995) (mandamus not issued where relief would be unavailing)
A Am. Stamp & Novelty Mfg. Co. v. Wettman, 658 S.W.2d 241 (Tex. App.—Houston [1st Dist.] 1983) (mandamus refused when subject matter is moot)
Williams v. Lara, 52 S.W.3d 171 (Tex. 2001) (case becomes moot when controversy ceases)
In re Fort Worth Star-Telegram, 441 S.W.3d 847 (Tex. App.—Fort Worth 2014) (describing rare capable-of-repetition-but-evading-review exception)
Ex parte Nelson, 815 S.W.2d 737 (Tex. Crim. App. 1991) (declining to apply exception where claim depended on speculative future parole violation)
Ex parte Bohannan, 350 S.W.3d 116 (Tex. Crim. App. 2011) (citing Nelson and rejecting speculative repetition claims)
Coburn v. Moreland, 433 S.W.3d 809 (Tex. App.—Austin 2014) (mere theoretical possibility insufficient for exception)
In re Bonilla, 424 S.W.3d 528 (Tex. Crim. App. 2014) (dismissing mandamus as moot where relief would be useless)