State v. Basile

Citations

• 2022 Ohio 3372

Syllabus

CRIMINAL LAW - court erred in failing to conduct a competency hearing once the issue of competency was raised, even though defense counsel withdrew the request, but such error was harmless appellant's angry outburst following sentencing was not indication of incompetency under the circumstances pursuant to Bryant, a defendant's outburst or other courtroom misbehavior is punishable as contempt of court but may not result in an increased sentence for the underlying crime a defendant's display of disrespect toward a court is not a permissible sentencing factor the content and context of appellant's outburst following sentencing did not indicate a lack of remorse affirmed, modified, and affirmed as modified.