State v. Ray

Citations

• 2019 Ohio 1346

Syllabus

107450 Substitute counsel Sixth Amendment breakdown in attorney-client relationship abuse of discretion consecutive sentences R.C. 2929.14(C)(4) affidavits. - Trial court did not abuse its discretion in not appointing substitute counsel for defendant where the defendant did not demonstrate a breakdown in the attorney-client relationship that would prevent appointed counsel from representing him in keeping with his Sixth Amendment rights trial court made the required findings under R.C. 2929.14(C)(4) to impose consecutive sentences appellate court could not consider affidavits attached to appellant's brief that were not part of the trial court record