State v. Simon

Citations

• 176 N.E.3d 1208
• 2021 Ohio 3090

Syllabus

COMPETENCY-WAIVER OF RIGHT TO COUNSEL - Despite Appellant's claim to be a Moorish American National and his defense to first degree felony charges based on faulty syntax, there was not sufficient indicia of incompetency to warrant trial court's sua sponte ordering a competency evaluation rather, Appellant's presence of mind to file documents and request continuances, along with his sometimes polite conduct and at other times uncooperative behavior, indicated a purpose to delay the proceedings and based on de novo review of the record, Appellant's waiver of the right to counsel was voluntary, knowing, and intelligent where trial court attempted to engage uncooperative defendant who refused appointed counsel and refused effective colloquy with the court.