State v. Givens

Citations

• 2025 Ohio 1438

Syllabus

To comply with the mandates of Crim.R 44(B), before accepting a criminal defendant's waiver of counsel trial court must engage in the requisite colloquy to advise of the dangers of proceeding pro se; violation of Crim.R. 44(B) does not affect underlying conviction, requires vacation of the sentence and resentencing without possibility of confinement, including a suspended sentence.