State v. Phipps

Citations

• 2022 Ohio 1188

Syllabus

The record does not reflect ineffective assistance of counsel based on defense counsel's trial strategy. Appellant's convictions for violating a protection order are valid notwithstanding the fact that the protection order was issued on an outdated form. The trial court did not err in denying appellant's request to discharge his attorney during trial. The trial court was not required to inquire into the reason for appellant's dissatisfaction where his complaint was not sufficiently specific. Judgment affirmed.