State v. Taylor, 2013 Ohio 1300

Taylor was convicted of domestic violence in a bench trial in the Tiffin Municipal Court after an August 2012 incident with Neely Phillips.
Arraignment occurred August 6, 2012; the court explained rights, penalties, and the option of counsel; Taylor pled not guilty.
Due to prior warrants and concerns, the court remanded Taylor to custody with no bond pending trial.
At trial on August 16, 2012, Taylor, proceeding pro se, requested a continuance for counsel but the court did not verify an indigent waiver and proceeded to trial.
The State presented Phillips’ testimony, officers’ testimony, and photos; Taylor was found guilty and sentenced to 180 days (120 suspended), two years’ probation, a $150 fine, and no-contact order.
Taylor timely sought appellate relief indicating indigent-counsel denial, weight/sufficiency challenges, and the propriety of holding him without bond.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Indigency and counsel appointment	Taylor was indigent and denied appointed counsel.	The court failed to ensure a valid waiver or provide counsel, violating rights.	First assignment sustained; improper waiver and denial of counsel prejudiced Taylor.
Weight and sufficiency of evidence	Evidence supported the conviction and weight favored the State.	Evidence was insufficient and against the weight of the evidence.	Mooted due to sustained first assignment; underlying merits not reached.
Holding defendant without bond	Holding without bond was permissible given circumstances.	Holding without bond without proper indigency proceedings violated rights.	Mooted due to sustained first assignment; not reached on its own.

State v. Wellman, 37 Ohio St.2d 162 (1974) (right to counsel in criminal prosecutions)
Argersinger v. Hamlin, 407 U.S. 25 (1972) (right to appointed counsel applies to offenses carrying jail time)
Gideon v. Wainwright, 372 U.S. 335 (1963) (indigent defendants have right to counsel)
Faretta v. California, 422 U.S. 806 (1975) (self-representation requires intelligent waiver of counsel)
State v. Tymcio, 42 Ohio St.2d 39 (1975) (waiver of counsel and trial rights considerations)
State v. Martin, 103 Ohio St.3d 385 (2004) (validity standards for intelligent, knowing waiver of counsel)
Von Moltke v. Gillies, 332 U.S. 708 (1948) (limitations on waiver of counsel; informed discretion)
State v. Suber, 154 Ohio App.3d 681 (2003) (waiver and continuance considerations in counsel decisions)
State v. Gibson, 45 Ohio St.2d 366 (1976) (counsel rights and waivers in Ohio)
State v. Dyer, 117 Ohio App.3d 92 (1996) (indigent defense and waiver standards)