State v. Howze

Citations

• 257 N.E.3d 1213
• 2024 Ohio 5447

Syllabus

CRIMINAL – Defense counsel's suspension for failure to pay continuing legal education fine during two-day trial did not constitute per se violation of Sixth Amendment right to counsel. No Sixth Amendment violation occurs where Appellant fails to show defense counsel's performance was deficient and that Appellant suffered outcome-determinative prejudice as a result. R.C. 2945.75(A)(2) does not apply to criminal statute that describes separate crimes in subsections. Order of forfeiture must be reversed and vacated where the trial court fails to conduct proportionality review.