State v. Hoskins

Citations

• 2026 Ohio 100

Syllabus

CRIM.R. 44 – CONCEALED CARRY – DANGEROUS ORDNANCE – SUFFICIENCY – WAIVER OF COUNSEL – WEAPONS UNDER DISABILITY – R.C. 2923.12 – R.C. 2923.13 – R.C. 2923.17: The trial court erred by failing to ensure that defendant knowingly, intelligently, and voluntarily waived his right to counsel, despite defendant's apparent unwillingness to engage in any good-faith discussion regarding his representation. Where the State charged defendant under the improper subsection of R.C. 2923.12, there was insufficient evidence to support defendant's conviction for carrying concealed weapons: defendant's weapon was a dangerous ordnance, and therefore, the evidence was insufficient to convict him under R.C. 2913.12(A)(2) of carrying a firearm other than a dangerous ordnance.