State v. Newman, 2020 Ohio 5087

Defendant Dazelle Newman was indicted on a consolidated 42-count indictment arising from an October 2016 crime spree (home invasion, shots fired at a vehicle, carjacking, high-speed police chases, ramming police cruisers, intentionally running over/assaulting and robbing a bicyclist).
Newman was initially appointed counsel, then insisted on proceeding pro se and waiving a jury; counsel and the court expressed concern given prior psychiatric referrals.
The court ordered a competency evaluation for the limited purpose of waiving counsel; Newman refused to cooperate with the clinic, so no new evaluation was completed.
The court relied on prior competency reports (finding Newman competent to stand trial, noting prior uncooperativeness/malingering), questioned Newman on the record, and accepted a written/in-court waiver of counsel; bench trial followed with Newman self-representing.
The trial court acquitted or dismissed some counts but convicted Newman on multiple counts and sentenced him to an aggregate 42-year term, consecutive to a separate 25-year sentence.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Newman)	Held
Whether the court abused discretion by allowing Newman to waive counsel and proceed pro se	The court properly ensured waiver was knowing and voluntary, attempted psychiatric evaluation, and relied on prior competency findings	Newman was likely incompetent to represent himself; the court should not have accepted his waiver after he was uncooperative with evaluators	Court affirmed: Newman competent to waive counsel under Godinez; waiver was knowing and voluntary; no abuse of discretion
Whether convictions were against the manifest weight of the evidence	Evidence (identifications, victim testimony, surveillance, recovered car and gun, cooperative witnesses, jail calls showing attempts to induce recantations) supports verdicts	Inconsistent/recanted witness statements and weak identifications render convictions against the weight of the evidence	Court affirmed: credibility/resolution of inconsistencies for factfinder; not an exceptional case warranting reversal

Godinez v. Moran, 509 U.S. 389 (competency to waive counsel uses competency-to-stand-trial standard)
Indiana v. Edwards, 554 U.S. 164 (trial courts may require higher competency for self-representation)
Faretta v. California, 422 U.S. 806 (criminal defendant has constitutional right to represent himself if waiver is knowing and voluntary)
State v. Martin, 103 Ohio St.3d 385 (Ohio requires sufficient inquiry to ensure waiver of counsel is knowing and intelligent)
State v. Thompkins, 78 Ohio St.3d 380 (standard for manifest-weight review)
State v. DeHass, 10 Ohio St.2d 230 (credibility and weight of testimony are for the trier of fact)