State v. Nelson, 75 N.E.3d 785

Jeffrey Nelson was indicted on multiple armed-robbery, kidnapping, and weapons charges; counsel was appointed due to indigency.
Nelson twice sought removal of appointed counsel, filed pro se waivers of counsel, and at a June 8 hearing expressly stated he wanted to represent himself after being warned of the disadvantages.
Counsel (Ionna) was reappointed at Nelson’s June 11 request, then orally moved to withdraw on June 19; the court granted withdrawal and denied Nelson’s request for a specific replacement attorney.
The court relied on Nelson’s earlier waiver and prior refusals of appointed counsel to proceed with Nelson pro se at the June 25 trial; Nelson requested a "legal coach" during trial but no new counsel was appointed.
Nelson was convicted on all counts and sentenced to an aggregate 54 years; he appealed arguing the court deprived him of his Sixth Amendment right to counsel and that he never knowingly, intelligently, and voluntarily waived counsel.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Nelson validly waived right to counsel	Nelson waived by written waiver and repeated refusals of appointed counsel; court afforded warnings — waiver may be inferred from conduct	Nelson never knowingly, intelligently, and voluntarily waived after counsel reappointed; court failed to perform sufficient inquiry and give adequate warnings at the critical June 19 withdrawal	Court: waiver was effective by written waiver plus defendant’s conduct; affirmed convictions
Whether the court’s procedure violated due process	State: procedures and warnings were sufficient; defendant’s repeated rejection of counsel justifies denial of further appointment	Nelson: record lacks clear knowing and intelligent waiver; denial of counsel after withdrawal violated due process	Court: declined to separately decide due-process claim (not argued separately)

Gideon v. Wainwright, 372 U.S. 335 (right to counsel is fundamental)
Faretta v. California, 422 U.S. 806 (defendant has constitutional right to proceed pro se when waiver is knowing and intelligent)
State v. Gibson, 45 Ohio St.2d 366 (Ohio standard for voluntary, knowing, intelligent waiver)
State v. Martin, 103 Ohio St.3d 385 (trial courts need only substantial compliance with Crim.R. 44; sufficient inquiry required)
United States v. Garey, 540 F.3d 1253 (waiver may be inferred from repeated refusal of competent counsel where court warned defendant)
King v. Bobby, 433 F.3d 483 (defendant’s rejection of appointed counsel and private counsel options can imply choice of self-representation)
United States v. Proctor, 166 F.3d 396 (waiver review standard; waiver not "set in stone")