State v. Furr, 2018 Ohio 2205

Defendant Kono Furr was charged with burglary (second-degree felony) and possessing criminal tools (fifth-degree felony).
Furr repeatedly told the court he did not want appointed counsel, asserted sovereign-citizen–style defenses, and refused to meet with a public defender.
The trial court conducted repeated colloquies, warned Furr about disadvantages of self-representation, explained charges, elements, defenses (including alibi), burdens of proof, and provided printed explanations.
The court ordered a competency evaluation after concerning statements; the evaluator found Furr competent to stand trial.
Furr initially refused to sign a written waiver but ultimately signed a waiver of counsel with the notation “under duress, without prejudice, reserve all rights.”
Furr appeared for trial in jail clothing without objecting; the court instructed jurors to disregard his attire.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether court deprived Furr of Sixth Amendment right to counsel by not having counsel present at all stages and by discharging counsel before a clear request to self-represent	State: Court complied with Crim.R. 44(A); thorough colloquy, competency exam, and offers of appointed counsel satisfied constitutional and rule requirements	Furr: Court committed structural error by allowing him to proceed pro se without counsel present during waiver process and by discharging counsel prematurely	Court: Overruled — Furr clearly and unequivocally waived counsel; court substantially complied with Crim.R. 44(A); no structural error
Whether trial court violated due process by compelling Furr to stand trial in identifiable jail clothing	State: Furr was not compelled; court asked twice whether he wanted civilian clothes and he did not object; judge instructed jurors to disregard attire	Furr: Wearing jail clothing prejudiced jury and violated due process	Court: Overruled — no compulsion shown, no contemporaneous objection, and jury instruction presumed followed

Gideon v. Wainwright, 372 U.S. 335 (1963) (right to counsel in serious criminal cases)
Faretta v. California, 422 U.S. 806 (1975) (defendant has right to represent self if waiver is knowing, intelligent, and voluntary)
Estelle v. Williams, 425 U.S. 501 (1976) (compulsion to stand trial in jail clothing can violate due process)
Montejo v. Louisiana, 556 U.S. 778 (2009) (waiver of counsel need not itself be counseled)
State v. Martin, 103 Ohio St.3d 385 (2004) (Crim.R. 44(A) substantial-compliance standard for waiver of counsel)