State v. Montgomery

Citations

• 2026 Ohio 1243

Syllabus

Telecommunications harassment; R.C. 2917.21(A)(1); Motion to Dismiss; Personal Jurisdiction; Self Representation; Crim.R. 44(B); Petty Offense; Hybrid representation; Sufficiency of the Evidence; Continuance. Defendant-appellant's telecommunications harassment conviction is based on sufficient evidence. The trial court did not err by denying the defendant-appellant's motion to dismiss the complaint because the trial court had personal jurisdiction over the defendant-appellant since he voluntarily appeared and pleaded not guilty to the charge in the complaint. Defendant-appellant's waiver of counsel was knowing, intelligent, and voluntary because the trial court substantially complied with the requirements of Crim.R. 44(B) by sufficiently inquiring in open court whether the defendant-appellant fully understood and relinquished his right to counsel. Standby counsel raising and arguing a Crim.R. 29 motion does not constitute improper hybrid representation.