State v. Hathorn

Citations

• 227 N.E.3d 438
• 2023 Ohio 3936

Syllabus

Competency Waiver of Counsel Standby Counsel Invited Error Expert Witness Sufficiency of the Evidence Prosecutorial Misconduct Merger Indefinite Sentences. Trial court did not err in failing to hold a sua sponte competency hearing when there was no indicia of incompetency. Waiver of counsel was properly made. Allowing standby counsel to conduct voir dire is invited error when appellant agreed to it. Expert witness was permitted to his own observations even if not an expert in that area. Evidence was sufficient to support the convictions. Alleged improper statements by the prosecutor did not outweigh the overwhelming evidence of guilt. Felonious assault and aggravated robbery convictions did not merge when they were two separate acts even though closely related in time. Indefinite sentence imposed pursuant to Reagan Tokes is constitutional.