Sweed, James Lee, WR-15,251-20

Relator Jimmy Lee Sweed filed a petition for writ of mandamus asking the Court of Appeals to compel Judge Bonnie Rangel of the 171st District Court (El Paso County) to rule on a post‑conviction motion in cause no. 69262.
Sweed contended the trial court had not ruled on the motion within a reasonable time and sought mandamus relief to force a ruling.
The Court of Appeals considered whether Sweed satisfied the standards for mandamus: clear abuse of discretion and lack of adequate appellate remedy.
The court reviewed the circumstances under which mandamus may compel a trial court to rule on a pending motion and the specific elements required for such relief.
The Court concluded Sweed failed to establish entitlement to mandamus and denied the petition.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion by failing to rule on a post‑conviction motion	Sweed: motion was properly filed, pending a reasonable time, and the court refused to rule — mandamus is warranted	Respondent: (implied) relator did not meet mandamus standards or failed to show refusal to rule / adequate grounds	Denied — Sweed failed to establish entitlement to mandamus
Whether mandamus is appropriate when an adequate appellate remedy exists	Sweed: no adequate remedy by appeal because the court declined to rule	Respondent: (implied) relator did not prove absence of an adequate appellate remedy	Denied — relator did not meet burden to show no adequate appellate remedy

In re Prudential Ins. Co. of Am., 148 S.W.3d 124 (Tex. 2004) (mandamus standards: clear abuse of discretion and lack of adequate appellate remedy)
In re Shredder Co., 225 S.W.3d 676 (Tex. App.—El Paso 2006) (mandamus may compel ruling on a motion pending for a reasonable time)
In re Hearn, 137 S.W.3d 681 (Tex. App.—San Antonio 2004) (same)
In re Chavez, 62 S.W.3d 225 (Tex. App.—Amarillo 2001) (same)