Euclid v. Hedge

Citations

• 2022 Ohio 464

Syllabus

Petty offense right to counsel invalid waiver remedy vacate conviction. Appellant charged with first-degree misdemeanor did not knowingly, intelligently, and voluntarily waive her right to counsel when the municipal court did not advise appellant of the dangers and disadvantages of self-representation, possible defenses, or any mitigating circumstances and made no inquiry into whether appellant was equipped to proceed with self-representation. The Supreme Court of Ohio resolves a split within the Eighth District that the appropriate remedy absent a valid waiver in petty offense cases is to vacate the conviction, not just the sentence of confinement and community-control sanction.