State v. Jordan, 2022 Ohio 2033

Vincent Jordan was indicted on two burglary counts (separate cases joined for trial) and a related possession-of-criminal-tools charge; he was represented by court-appointed counsel.
Throughout pretrial proceedings Jordan repeatedly complained about counsel (poor communication), requested new counsel, behaved disruptively, and sometimes refused to attend court.
The trial court repeatedly inquired into Jordan’s complaints, offered the option of new counsel (with delay), and concluded many complaints were vague or delay tactics.
At trial Jordan was held in a holding cell (allowed to observe); he intermittently requested to represent himself, interrupted the court during a Faretta colloquy, then left the courtroom.
After limited trial proceedings (one witness called), Jordan met with counsel and the parties entered a joint recommendation: guilty pleas to burglary counts in the two cases (one second-degree, one third-degree); remaining charge dismissed; concurrent sentences recommended and adopted.
Jordan appealed, raising three assignments: denial of substitute counsel (effective-assistance claim), denial of a continuance to prepare to self-represent, and that his guilty pleas were not knowing/voluntary; the appellate court affirmed.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Jordan)	Held
Whether trial court abused discretion by denying substitute counsel	Court properly inquired; complaints were vague/delay tactics; no breakdown of advocacy	Counsel conflicted with Jordan and appellate counsel appointment was required	Denied; no abuse of discretion — complaints were vague and did not show a total breakdown; plea forms showed satisfaction with counsel
Whether trial court abused discretion by denying continuance to allow Jordan to prepare to represent himself	Jordan never unequivocally invoked Faretta right; when he did, he was disruptive and waived the request; delay would be unwarranted	Jordan sought time to prepare to proceed pro se	Denied; no abuse of discretion — right to self-representation not properly invoked and was effectively waived
Whether guilty pleas were knowing, voluntary, and intelligent given the above rulings	Crim.R. 11 colloquy was adequate; Jordan admitted understanding and signed plea forms stating satisfaction with counsel; pleas were voluntary	Pleas coerced by denial of new counsel and denial of continuance to prepare pro se	Denied; pleas were knowingly, intelligently, and voluntarily made; Crim.R. 11 requirements satisfied

Faretta v. California, 422 U.S. 806 (1975) (recognizes constitutional right to self-representation).
State v. Coleman, 37 Ohio St.3d 286 (1988) (defendant must show attorney-client breakdown that jeopardizes right to counsel to discharge court-appointed counsel).
State v. Gibson, 45 Ohio St.2d 366 (1976) (Ohio recognizes Faretta right; waiver must be voluntary, knowing, intelligent).
State v. Cassano, 96 Ohio St.3d 94 (2002) (right to self-representation must be unequivocally invoked).
State v. Obermiller, 147 Ohio St.3d 175 (2016) (defendant may waive self-representation by acquiescing to counsel; courts should presume against waiver).
Unger v. State, 67 Ohio St.2d 65 (1981) (continuance decisions reviewed for abuse of discretion).
Blakemore v. Blakemore, 5 Ohio St.3d 217 (1983) (abuse-of-discretion standard defined).
McKaskle v. Wiggins, 465 U.S. 168 (1984) (defendant may accept standby counsel; limits on claim that counsel infringed on pro se rights).