A 388 petition filed in pro per by a parent who is represented by counsel need not be considered by the juvenile court. Shortly before a section 366.26 hearing, Mother filed a pro per section 388 petition requesting reunification services and liberalized visitation. The juvenile court denied the petition summarily and proceeded to terminate parental rights. Mother appealed and the reviewing court affirmed. Generally, a litigant represented by counsel has access to the court through counsel and thus has no right also to submit pro per filings. There are exceptions for pro per motions regarding representation (People v. Marsden (1970) 2 Cal.3d 118) and notices of appeal. Here, Mother’s 388 petition did not relate to her representation and thus, was not properly before the court.

The full opinion is available on the court’s website here: https://www4.courts.ca.gov/opinions/documents/E087969.PDF