State v. Robinson

Citations

• 2018 Ohio 5036

Syllabus

Waiver of counsel knowingly, voluntarily, intelligently sufficient inquiry nature of the charges defenses and mitigating circumstances standby counsel. Trial court did not make sufficient inquiry to determine if the defendant understood and knowingly waived his right to counsel where the court did not adequately explain the nature of the charges to the defendant, and did not discuss with him any possible defenses and mitigating circumstances. The trial court also erroneously advised the defendant that he could not ask questions of appointed standby counsel. Thus, the defendant's waiver of counsel was not knowingly, voluntarily, and intelligently made.