State v. Coker, 2021 Ohio 2910

Marcus Coker was indicted in 2017 on multiple charges including aggravated murder, murder, felony murder, felonious assault, kidnapping, and failure to comply; repeat violent offender specifications were alleged.
Coker moved to dismiss trial counsel and elected to represent himself; standby counsel were appointed and the State’s motion to join related indictments was granted.
Coker entered no-contest pleas in two joined cases pursuant to a plea agreement that made repeat-violent-offender specifications discretionary and dismissed charges in a third case.
After plea, Coker moved pre-sentence to withdraw his pleas; the trial court held a hearing, denied the motion, merged counts for sentencing, and imposed life with parole eligibility after 30 years plus a consecutive 12-month term (total 31 years to life), consecutive to sentence in the other case.
Coker obtained delayed appeal; appellate counsel raised two assignments of error: (1) trial court sua sponte should have ordered a competency evaluation, and (2) trial court abused discretion by denying the pre-sentence motion to vacate pleas. The appellate court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court abused discretion by failing to sua sponte order a competency evaluation	Coker: his statements and behavior showed indicia of incompetence requiring a competency evaluation	State/Trial Ct: record shows rational understanding of charges, coherent participation, valid Faretta waiver, and unconventional beliefs do not alone require evaluation	Court held no abuse; competency presumed and not rebutted by record; assignment overruled
Whether trial court abused discretion in denying pre-sentence motion to withdraw pleas	Coker: he did not receive a full and fair hearing and lacked counsel at the hearing; he could show evidence of innocence	State/Trial Ct: plea colloquy was thorough; Coker declined to present evidence or request more time; he knowingly proceeded pro se with standby counsel	Court held denial was not an abuse of discretion; Coker failed to show a legitimate basis to withdraw pleas; assignment overruled

Anders v. California, 386 U.S. 738 (procedure for appointed counsel to move to withdraw when appeal is frivolous)
Godinez v. Moran, 509 U.S. 389 (competency standard applies to plea and waiver of counsel)
Dusky v. United States, 362 U.S. 402 (standard for competency to stand trial)
Pate v. Robinson, 383 U.S. 375 (procedures protect incompetent defendants from being tried)
Faretta v. California, 422 U.S. 806 (right to self-representation and attendant risks)
Blakemore v. Blakemore, 5 Ohio St.3d 217 (abuse-of-discretion standard)
State v. Jordan, 101 Ohio St.3d 216 (presumption of competency and related discussion)
State v. Mink, 101 Ohio St.3d 350 (quoting Dusky on competency standard)
State v. Berry, 72 Ohio St.3d 354 (due process requires protecting incompetent defendants from trial)