State v. Gibson, 2014 Ohio 1169

Gibson and Quarterman had a six-year relationship; they reconnected January 12–13, 2013 regarding belongings left at Gibson's home.
Quarterman rented a two-day room at Perry Inn on January 13, 2013; Gibson assaulted her in Room 122, beating her for 10–15 minutes.
Quarterman attempted to flee naked with clothes in hand; Gibson dragged her back by her hair, then she escaped and called 911.
Officers found Quarterman with significant facial injuries; Gibson asleep in the room, naked, with blood on sheets; he claimed no knowledge of the injuries.
Gibson was charged with felonious assault (R.C. 2903.11(A)(1)) and abduction (R.C. 2905.02(A)(2)); he initially had counsel but proceeded pro se with standby counsel appointed.
He was convicted by jury and sentenced to 8 years for felonious assault and 36 months for abduction, run concurrently.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the waiver of counsel knowing, intelligent, and voluntary?	Gibson argues waiver was defective.	Gibson contends the waiver was valid and voluntary.	Waiver was knowing, intelligent, and voluntary.
Did sentencing for felonious assault punish Gibson for exercising his right to trial?	Gibson asserts sentence was punitive for choosing trial.	State argues no punitive purpose shown and no record of coercion.	No evidence the court punished Gibson for going to trial; sentence upheld.
Is the evidence sufficient to support felonious assault and abduction convictions?	Quarterman’s testimony suffices to prove guilt.	Sufficiency requires more corroboration; challenged credibility of victim’s account.	Evidence, viewed in the light most favorable to the state, suffices to support both convictions.

Faretta v. California, 422 U.S. 806 (1975) (right to self-representation requires a knowing, intelligent, and voluntary waiver)
Von MoLtke v. Gillies, 332 U.S. 708 (1948) (pretrial inquiry must inform defendant of charges, defenses, and penalties for valid waiver)
State v. Gibson, 45 Ohio St.2d 366 (1976) (test for knowing waiver of counsel; comprehensive examination)
Iowa v. Tovar, 541 U.S. 77 (2004) (waiver of right to counsel must be knowing, voluntary, and intelligent)
State v. Ebersole, 107 Ohio App.3d 288 (1995) (importance of knowing, voluntary waiver when self-representation is chosen)
O'Dell, 45 Ohio St.3d 140 (1989) (punishing a defendant for exercising right to trial; standards for sentencing after trial)
State v. Morris, 159 Ohio App.3d 775 (2005) (absence of unequivocal record that trial choice affected sentence; reversal if present)
State v. Thompkins, 78 Ohio St.3d 380 (1997) (sufficiency review focuses on whether evidence could support a conviction if believed)
State v. Jenks, 61 Ohio St.3d 259 (1991) (standard for reviewing sufficiency of the evidence)