State v. Price, 2015 Ohio 411

Price was charged in 2013 with two counts each of drug trafficking and drug possession, plus possession of criminal tools, with forfeiture requests on the items.
Public defender services were substituted for defense counsel due to withdrawal and indigency; Price ultimately proceeded to trial with self-representation aided by a court-appointed advisor.
Detectives surveilled Price’s North Olmsted residence for five months, observed him with rental cars, and obtained a search warrant.
A search of Price’s vehicle and apartment uncovered cocaine, a scale, and cash, with field tests confirming cocaine; authorities recovered substantial quantities in multiple locations.
Price admitted ownership of the seized drugs and money during a post-arrest interview; he later attempted to modify his counsel and sought self-representation, which the court accommodated with conditions.
The jury found Price guilty on all counts, with forfeiture limited to the scale and money; sentencing included a 11-year term with postrelease control, and the court later addressed court costs on remand.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Right to counsel substitution	Price argues his Sixth Amendment right to counsel was violated.	Price contends error in denying substitution of counsel and forcing self-representation.	No abuse; denial was reasonable, not a delay tactic.
Competency/psychological evaluation	Price sought a psychological evaluation to stand trial himself.	Competency evaluation was improper delay tactic.	Court did not abuse discretion; evaluation denied as a delay tactic.
Sufficiency of the evidence	State failed to prove Price resided at the North Olmsted address.	Evidence showed Price’s residence at the apartment.	Sufficient evidence supported residence finding.
Manifest weight of the evidence	Convictions were against the manifest weight given admissions and possession.	Alternative theories and credibility issues undermine weight.	Convictions not against the manifest weight.
Court costs	Costs were improperly imposed without open-court ruling.	Remand necessary to address cost waiver.	Remand for limited purpose to address court-cost waiver.

State v. Keenan, 81 Ohio St.3d 133 (1998) (right to counsel of choice is presumptive; balance with fairness)
United States v. Gonzalez‑Lopez, 548 U.S. 140 (2006) ( Sixth Amendment right to counsel not absolute; effectiveness matters)
State v. Henness, 79 Ohio St.3d 53 (1997) (absence of rapport is not fatal to counsel rights)
Morris v. Slappy, 461 U.S. 1 (1983) (right to counsel is not absolute; trial court has discretion)
State v. Thompkins, 78 Ohio St.3d 380 (1997) (standard for sufficiency and weight; appellate review guidance)
State v. Antill, 176 Ohio St. 61 (1964) (factfinder may choose among competing inferences)
State v. Joseph, 125 Ohio St.3d 76 (2010) (remand when court costs imposed in journal but not open court)
State v. Gipson, 80 Ohio St.3d 626 (1998) (indigency and mandatory fines framework)