State v. Crider, 2014 Ohio 2240

Crider was indicted in Allen County on eight counts including rape, sexual battery, kidnapping, and gross sexual imposition arising from two separate assaults on a relative victim in September 2012.
Crider waived counsel after repeatedly stating he wished to fire his attorney and elected to represent himself, with the court conducting a thorough exchange about the waiver and trial risks.
Crider unsuccessfully sought a continuance after waiving counsel; the trial proceeded with Crider representing himself and the State dismissing count 8.
A jury found Crider guilty on seven counts; allied-offense findings merged certain counts, and sentencing occurred with consecutive terms on remaining counts.
The trial court imposed concurrent/concurring sentences totaling multiple years; the judgment faced appellate challenges on waiver validity, continuance denial, ineffective assistance, consecutive-sentence findings, and various constitutional/indictment issues.
The court ultimately affirmed in part, reversed in part, and remanded for proceedings consistent with its opinion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Waiver of counsel and self-representation valid?	Crider contends waiver was involuntary.	Crider asserts he did not knowingly and intelligently waive counsel.	Waiver valid; decision to represent himself affirmed.
Denial of continuance after waiver was proper?	Crider claims denial prejudiced his defense.	State argues no abuse of discretion and Crider contributed to delays.	No abuse; denial affirmed.
Ineffective assistance of counsel prior to waiver	Crider asserts counsel’s performance deprived him of a fair trial.	Counsel’s strategy not shown to be prejudicial.	No reversible ineffective-assistance finding; failure to request discovery was strategic and harmless.
Consecutive-sentencing findings on the record	Findings required by RC 2929.14(C)(4) must appear at sentencing.	Court can rely on journal entry for the findings.	Error; findings not made on the sentencing record; proceedings remanded.
Indictment notice and carbon-copy indictment issues (Fifth–Seventh assignments)	Argument about notice, due process, double jeopardy, and a carbon-copy indictment.	Indictment sufficiently apprised Crider of offenses; no carbon-copy defect.	Fifth: not reviewable; Sixth: indictment sufficient; Seventh: not a carbon-copy indictment.

State v. Gibson, 45 Ohio St.2d 366 (Ohio 1976) (Sixth Amendment right to counsel; waiver must be valid.)
Johnson v. Zerbst, 304 U.S. 458 (U.S. 1938) (Right to counsel and its waiver analysis.)
State v. Owens, 2008-Ohio-4161 (3rd Dist. Allen 2008) (Authority on per se waiver standards (discussion cited by court).)
State v. Calhoun, 86 Ohio St.3d 279 (1999) (Ineffective assistance and substantial rights analysis.)
State v. Hester, 45 Ohio St.2d 71 (Ohio 1976) (Two-step test for ineffective-assistance claims.)
State v. Lytle, 48 Ohio St.2d 391 (Ohio 1976) (Framework for evaluating ineffective-assistance claims.)
Valentine v. Konteh, 395 F.3d 626 (6th Cir. 2005) (Indictment notice and double jeopardy considerations.)
Russell v. United States, 369 U.S. 749 (U.S. 1962) (Required elements and notice to be prepared to meet.)
Unger, State v. Unger (Ohio 1981) (Discretion in continuance determinations.)