State v. Corder, 95 N.E.3d 756

Steven L. Corder was indicted on five sexual-offense counts; after trial the jury convicted him of one count of gross sexual imposition and the bench convicted him of unlawful sexual conduct with a minor; total sentence 10 years (consecutive).
Months before trial Corder told the court he wanted to fire appointed counsel; the court denied that request and continued the case.
Corder later filed multiple pro se motions alleging specific deficiencies by counsel (failure to obtain records, failure to communicate, failure to investigate/parole-board materials); the trial court did not rule on or orally inquire into those motions and stated it would not read pro se filings because Corder had counsel.
At trial the State presented testimony from the alleged victim and a detective (the detective gave lay-opinion-type testimony about typical juvenile disclosure behavior and was not qualified as an expert). There was no physical evidence preserved.
After conviction the appellate court found the trial court failed to conduct the required on-the-record inquiry into Corder’s specific complaints about counsel and reversed and remanded for that Deal inquiry; if complaints are unfounded the court may re-enter judgment, but if well-founded Corder is entitled to new trial or discharge (if state declines retrial). The consecutive-sentence and detective-opinion issues were rendered moot/unripe by that disposition.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by failing to inquire into Corder's requests to dismiss appointed counsel	State: Corder waived the issue by not asserting it at trial	Corder: He repeatedly raised specific complaints (pretrial and pro se) and the court had a duty to inquire	Reversed and remanded: court failed to conduct required Deal inquiry; relief depends on outcome of inquiry
Whether sentencing findings under R.C. 2929.14(C)(4) were inadequate for consecutive terms	State: sentencing complied; issue forfeited by appeal posture	Corder: trial court failed to make statutory consecutive-sentence findings	Moot (remanded on Deal inquiry first; could be reconsidered later if convictions reinstated)
Whether detective improperly testified about typical juvenile disclosure without being qualified as an expert	State: testimony admissible lay/experience evidence	Corder: testimony amounted to impermissible expert opinion and prejudiced him	Unripe/moot (may be raised again if convictions stand or on retrial)
Whether counsel’s alleged failures deprived Corder of Sixth Amendment effective representation	State: no reversible error; waiver or not sufficiently specific	Corder: specific allegations (lack of communication, failure to obtain evidence) undermined representation	Sustained in part: factual inquiry required under Deal; outcome depends on inquiry findings

United States v. Gonzalez-Lopez, 548 U.S. 140 (2006) (right to counsel of choice is structural but limited for appointed counsel)
Wheat v. United States, 486 U.S. 153 (1988) (trial court has discretion balancing counsel choice against fairness and court administration)
State v. Deal, 17 Ohio St.2d 17 (1969) (trial court must conduct on-the-record inquiry when defendant makes specific complaints about appointed counsel)
State v. Jones, 91 Ohio St.3d 335 (2001) (factors for substitution of counsel: timeliness, adequacy of inquiry, and whether conflict prevents adequate defense)