State v. Woodard

Citations

• 2019 Ohio 251

Syllabus

Presentence motion to withdraw guilty plea, Crim.R. 32.1, right to counsel, waiver. The absence of a thorough colloquy concerning the defendant's waiver of trial counsel and request for appointment of new trial counsel establishes that the defendant did not knowingly, voluntarily, and intelligently waive his right to counsel and that the defendant was denied his constitutional right to counsel. Therefore, his convictions are vacated, and the case is remanded for the trial court to hold (1) a hearing to advise the defendant of the perils of self-representation and determine whether the defendant should be appointed new counsel, and (2) a hearing on the defendant's presentence motion to withdraw his guilty plea.