State v. Griffin, 2013 Ohio 5389

Griffin was convicted after a jury trial of carrying a concealed weapon, improper handling of a firearm in a motor vehicle, and possession of cocaine; the stop and inventory search led to discovery of a loaded handgun and cocaine.
The November 9, 2011 traffic stop occurred with Griffin as the driver; he was arrested for lacking a valid license, and the car was impounded.
An inventory search of the impounded vehicle yielded the handgun and cocaine.
Griffin was indicted January 30, 2012 on four counts including weapon-related offenses and cocaine possession.
Trial began July 23, 2012; the jury convicted on counts 1–3, the court found Griffin guilty on the weapon-under-disability count 4, and Griffin was sentenced August 10, 2012.
On appeal Griffin challenged (1) the court’s denial of his request to substitute counsel and (2) his trial counsel’s failure to file a motion to suppress evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court erred by denying Griffin's request for new counsel.	Griffin asserted a Sixth Amendment right to counsel of choice was violated.	Griffin claimed dissatisfaction with counsel justified substitution.	No reversible error; court did not abuse discretion in denying substitution.
Whether Griffin received ineffective assistance of counsel for not filing a suppression motion.	Evidence should have been suppressible as illegally obtained or improperly seized.	Counsel was not ineffective for failing to challenge a valid inventory search.	No reversible error; suppression motion would have been futile.

United States v. Gonzalez-Lopez, 548 U.S. 140 (2006) (right to counsel of choice has limits in balancing fairness and docket control)
Wheat v. United States, 486 U.S. 153 (1988) (courts balance right to counsel with calendar control when substituting counsel)
Morris v. Slappy, 461 U.S. 1 (1983) (courts may delay proceedings only for compelling reasons when changing counsel)
State v. Williams, 99 Ohio St.3d 439 (2003) (general dissatisfaction with counsel requires specific inquiry; no breakdown in communications)