State v. Schleiger (Slip Opinion), 141 Ohio St. 3d 67

Schleiger was convicted of felonious assault and carrying a concealed weapon in 2009, with consecutive sentences of eight years and 18 months.
On remand for proper imposition of postrelease control, the resentencing hearing occurred under R.C. 2929.191 after initial sentencing.
At the resentencing, Schleiger elected to represent himself after conferring with standby counsel who remained in court.
The trial court imposed three years of mandatory postrelease control and admonished Schleiger on its consequences.
The appellate court held that counsel was not required at a resentencing limited to imposing postrelease control, creating a conflict with Peace.
Supreme Court accepted the certified question: whether counsel is required at a resentencing for postrelease control; held that the right attaches but Schleiger validly waived it.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Right to counsel at postrelease-control resentencing	Schleiger: resentencing for postrelease control is a critical stage requiring counsel.	State: limited, ministerial correction; no need for counsel; waiver valid.	Right attaches, but waiver valid; affirmed judgment.

United States v. Wade, 431 U.S. 218 (U.S. 1967) (critical stages include trial-like confrontations where counsel helps)
Iowa v. Tovar, 541 U.S. 77 (U.S. 2004) (no fixed script for waivers; factors depend on case-specific context)
Gardner v. Florida, 430 U.S. 349 (U.S. 1977) (sentencing is a critical stage; defendant has interest in procedure)
Mempa v. Rhay, 389 U.S. 128 (U.S. 1967) (right to attorney at probation-revocation-type proceedings)
Woods v. Telb, 89 Ohio St.3d 504 (Ohio 2000) (postrelease-control terms are part of the sentence)
State v. Fischer, 128 Ohio St.3d 92 (Ohio 2010) (statutory imposition of postrelease-control; proper procedure)
State v. Peace, 2012-Ohio-6118 (Ohio 2012) (conflicting view on right to counsel at postrelease-control resentencing)