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State v. Clifton

Citations

  • 2026 Ohio 2122

Syllabus

Defendant had history of mental health issues. Defendant began refusing to meet with counsel before trial and engaged in outbursts during trial. Defendant claimed ineffective assistance of counsel for failing to move for a competency hearing. Record did not contain sufficient indicia of incompetency to trigger duty to move for competency hearing. Refusal to meet with counsel appeared to be a choice. Outbursts during trial indicated frustration, not lack of capacity to understand proceedings or assist in defense.

Judges: Byrne

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Cites

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