State v. Lee

Citations

• 2020 Ohio 3987

Syllabus

In a murder trial, it was structural error for the trial court to accept appellant's waiver of his right to counsel and proceed to trial without a continuance. Appellant's waiver of his right to counsel, which occurred on a Thursday, was equivocal and unclear he asserted his right to self-representation yet further asserted that he was unprepared to proceed to trial pro se the following Monday and needed a continuance. Judgment reversed and remanded. (Froelich, J., concurring in judgment only.) (Tucker, P.J., dissenting.)