State v. Barron

Citations

• 2024 Ohio 5836

Syllabus

The trial court did not abuse its discretion by denying appellant's request to exercise his right of self-representation; the request was untimely, and appellant exhibited confusion while the trial court was determining whether appellant was knowingly, intelligently, and voluntarily waiving his right to counsel. The trial court did not err by failing to merge appellant's felonious assault, domestic violence, and abduction offenses at sentencing, because the offenses resulted in separate, identifiable harm and were committed separately. Appellant's conviction for abduction was supported by sufficient evidence, and none of appellant's convictions were against the manifest weight of the evidence. Appellant's claim that his trial counsel provided ineffective assistance by failing to subpoena certain witnesses for trial lacks merit because such a decision is a matter of trial strategy, which cannot form the basis of an ineffective assistance of counsel claim. Judgment affirmed.