State v. Belt, 2020 Ohio 1302

Officer stopped Mark Belt after observing erratic driving and learned Belt had twelve open license suspensions; vehicle was towed and inventoried.
Inventory search of the vehicle uncovered multiple items that together appeared to form a functional methamphetamine lab.
Belt was indicted on one count of aiding and abetting the illegal assembly/possession of chemicals for methamphetamine and one count of possession of criminal tools; he pled not guilty and proceeded to a jury trial.
On the second day of trial Belt expressed that he believed he could represent himself and that appointed counsel “stutters,” but did not explicitly or unequivocally ask to waive counsel.
The trial court declined to permit self-representation because the trial had already begun and counsel had been appointed; Belt was convicted on both counts and sentenced to an aggregate 48 months.
On appeal Belt argued the trial court violated his Sixth Amendment right to waive counsel and proceed pro se; the appellate court affirmed, finding no unequivocal invocation of the right to self-representation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court violated the Sixth Amendment by refusing Belt's request to represent himself	State: Belt never made an unequivocal, explicit invocation of his Faretta right; court properly kept appointed counsel in place once trial had begun	Belt: He told the court he could better represent himself, had done legal research, and wanted to proceed pro se to protect his liberty	Appellate court: Belt’s remarks did not constitute an unequivocal waiver or explicit request to proceed pro se; no constitutional violation

Faretta v. California, 422 U.S. 806 (U.S. Supreme Court recognizing constitutional right to self-representation)
State v. Johnson, 112 Ohio St.3d 210, 858 N.E.2d 1144 (Ohio Supreme Court discussing required inquiry for waiver of counsel)
State v. Martin, 103 Ohio St.3d 385, 816 N.E.2d 227 (waiver must be knowing, voluntary, and intelligent; matters to be understood listed)
State v. Cassano, 96 Ohio St.3d 94, 772 N.E.2d 81 (request for self-representation must be unequivocal and explicit)
United States v. Frazier–El, 204 F.3d 553 (courts should guard against manipulation of mutual exclusivity of rights to counsel and self-representation)
Brewer v. Williams, 430 U.S. 387 (courts should indulge every reasonable presumption against waiver of constitutional rights)
State v. Gibson, 45 Ohio St.2d 366, 345 N.E.2d 399 (trial court must inquire to ensure defendant understands and intelligently relinquishes right to counsel)
Von Moltke v. Gillies, 332 U.S. 708 (waiver must be made with apprehension of nature of charges and consequences)
State v. Suber, 154 Ohio App.3d 681, 798 N.E.2d 684 (discussing breadth of information a defendant should understand before waiving counsel)