State v. Phipps, 2022 Ohio 1188

Phipps was charged with six misdemeanor counts for calling a protected person from jail in violation of a domestic-violence protection order issued after an alleged assault.
He rejected a plea offer (one count) because he feared parole consequences from a Wisconsin conviction.
At a bench trial the State presented: (1) a deputy who served the order; (2) a parole officer who identified voices on six recorded jail calls (Apr 27–May 2); and (3) a detective who authenticated the recordings and testified that the protected person later sought termination of the order (Apr 29) and an entry terminating it was filed May 3.
The court convicted Phipps of three violations occurring Apr 27–29 and acquitted him of three calls after Apr 29 (when the protected person moved to terminate).
Sentencing: consecutive 180-day jail terms with credit for time served, remainder suspended, plus non-reporting probation.
On appeal Phipps raised three claims: (1) ineffective assistance of trial counsel; (2) the protection order was invalid because it used an outdated form; and (3) the trial court failed to inquire when he said he wanted to fire counsel.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ineffective assistance of counsel	State: counsel’s strategy was reasonable; no deficient performance or prejudice	Phipps: counsel improperly attacked the protection order and elicited his acknowledgment of receipt, possibly costing him the plea	Court: Overruled — counsel’s performance was reasonable trial strategy and no prejudice shown
Validity of protection order (outdated form)	State: pre- and post-Apr 15 forms are substantially similar; Phipps was shown/served with the order	Phipps: order used pre-Apr 15 form (Form 10-D), so it was invalid on its face	Court: Overruled — any form defect did not render order void; Phipps was served/shown the order and statutory requirements met
Trial court duty to inquire when defendant sought to "fire" counsel	State: no duty to investigate absent specific, particularized allegations	Phipps: court should have inquired into his claim of ineffective representation	Court: Overruled — defendant’s statement that counsel had not "fully represented" him was too vague to trigger the duty to investigate (Deal limited to specific allegations)

Strickland v. Washington, 466 U.S. 668 (establishes two-prong ineffective-assistance test)
State v. Bradley, 42 Ohio St.3d 136 (Ohio application of Strickland)
State v. Hale, 119 Ohio St.3d 118 (prejudice is a reasonable-probability standard)
State v. Woullard, 158 Ohio App.3d 31 (debatable trial strategy not IAC)
State v. Deal, 17 Ohio St.2d 17 (trial judge must inquire when defendant makes specific allegations about counsel)
State v. Johnson, 112 Ohio St.3d 210 (duty to investigate arises only for sufficiently specific claims)