State v. Moore, 2019 Ohio 2633

On Jan 3, 2016 police responded to a Best Western in Napoleon, Ohio after a guest (Moore) allegedly left without paying; complaint for theft (first-degree misdemeanor) filed Jan 7, 2016.
A warrant issued when Moore could not be located; he was arrested on Dec 6, 2018 and viewed a video of his rights before arraignment.
Arraigned Dec 7, 2018: plea of not guilty entered; pretrial set.
Dec 10, 2018 pretrial/change-of-plea hearing by video: Moore waived counsel, proceeded pro se, executed a written Crim.R. 11 waiver, entered a no-contest plea, and was found guilty.
Court sentenced Moore the same day to 30 days (26 suspended) with 4 days credit, ordered restitution and costs, then released him; Moore filed a timely notice of appeal.
On appeal Moore raised numerous constitutional and procedural complaints (Miranda, due process, right to counsel, coercion, insufficiency, statutory violation), but provided no legal authority or developed argument and failed to comply fully with appellate briefing rules.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court erred in accepting Moore’s no-contest plea and convicting him	State: Proceedings complied with Crim.R. 11; plea and waiver were valid	Moore: Plea coerced; lacked capacity; rights (Miranda, counsel, presumption of innocence, due process) violated; guilt not proven	Court: Overruled — Moore failed to identify record error or cite authority; App.R.16/12 allow disregarding inadequately briefed claims
Whether appellate relief (set aside conviction) is warranted	State: No reversible error shown	Moore: Seeks reversal and setting aside of conviction on multiple constitutional grounds	Court: Denied — appellant bears burden to demonstrate error; Moore did not meet it
Procedural compliance with appellate rules (requests for counsel/transcripts/delayed appeal)	State: N/A (court enforced rules)	Moore: Requested appointment of counsel and transcripts, motion for delayed appeal	Court: Denied appointment and transcript motions for being filed in wrong forum; delayed appeal moot because notice was timely
Whether the appellate court must seek or supply arguments absent adequate briefing	State: N/A	Moore: Implicitly asks court to address substantive claims despite sparse briefing	Court: Held it is not court’s duty to develop arguments; may decline to address inadequately presented issues

Hawley v. Ritley, 35 Ohio St.3d 157 (1988) (appellate courts may disregard assignments of error not properly presented)
Meerhoff v. Huntington Mtge. Co., 103 Ohio App.3d 164 (3d Dist. 1995) (appellate courts need not address issues unsupported by authority or insufficient briefing)