State v. Deloney

Citations

• 2025 Ohio 2458

Syllabus

COMPETENCY TO STAND TRIAL – CONFRONTATION CLAUSE – CIV.R. 43(A) – JUROR BIAS – FARETTA – RIGHT OF SELF-REPRESENTATION – INEFFECTIVE ASSISTANCE OF COUNSEL: The trial court did not err in failing to order a competency hearing sua sponte where defendant was previously found competent to stand trial and subsequent facts and events did not create a sufficient doubt about his competency. The trial court did not err in determining that defendant's absence from trial was voluntary where defendant was offered the opportunity to appear in court each day and failed to present evidence to corroborate that his injuries or medications prevented him from participating at trial. The trial court did not plainly err in failing to strike two jurors sua sponte for bias where one was rehabilitated and the other's responses were merely ambiguous. Defendant did not receive constitutionally ineffective assistance where counsel failed to strike two jurors either peremptorily or for-cause, but where one juror was rehabilitated and the other juror's answers were merely ambiguous. The trial court did not err by denying defendant's request to represent himself made on the third day of voir dire, as the request was untimely. Even assuming counsel was ineffective for failing to secure the suppression of defendant's confession and exclusion of testimony of the State's facial-recognition expert, defendant's Sixth Amendment rights were not violated because defendant failed to show that the admission of either the confession or the expert testimony prejudiced him.