43 Ohio opinions name it 2 courts 1990–2026 7 in the last five years
The cases below were cited by Ohio courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
State v. Dealgreen2 sentences2026PAGE 8 OF 19 Case No. 2025-L-073 First Assignment of Error: Motion for New Counsel; Standard of Review {¶30} “Where, during the course of his trial for a serious crime, an indigent accused questions the effectiveness and adequacy of assigned counsel, … it is the duty of the trial judge to inquire into the complaint and make such inquiry a part of the record.” State v. Deal, 17 Ohio St.2d 17 (1969), syllabus. 2025"Where, during the course of his trial for a serious crime, an indigent accused questions the effectiveness and adequacy of assigned counsel, * * * it is the duty of the trial judge to inquire into the complaint and make such inquiry a part of the record." State v. Deal, 17 Ohio St.2d 17 , syllabus (1969). | 2 | 41 |
State v. Kinggreen2 sentences2011The Fourth District held that, “[if], during trial an indigent defendant questions the effectiveness and adequacy of assigned counsel, it is the duty of the trial court to inquire into the complaint and make the inquiry part of the record.” State v. King, 104 Ohio App. 3d 434, 437 (1995). {¶19} This Court has held that “[a]n indigent defendant has a right to competent counsel, not a right to counsel of his own choosing.” State v. Harrison, 9th Dist. 2006In proposition VII, Ketterer further argues that the “trial court erred by failing to hold a hearing when Ketterer announced in court that he wanted to ‘fire’ his lead counsel.” Ketterer relies upon State v. Deal (1969), 17 Ohio St.2d 17 , 46 O.O.2d 154 , 244 N.E.2d 742 , syllabus, wherein this court held that when “an indigent accused questions the effectiveness and adequacy of assigned counsel, * * * it is the duty of the trial judge to inquire into the complaint and make such inquiry a part of the record.” See, also, State v. King (1995), 104 Ohio App.3d 434, 437 , 662 N.E.2d 389 (“inquiry | 2 | 8 |
State v. Cartergreen2 sentences2022This " 'limited judicial duty arises only if the allegations are sufficiently specific; vague or general objections do not trigger the duty to investigate further.' " Johnson at ¶ 68, quoting State v. Carter, 128 Ohio App.3d 419, 423 (4th Dist.1998). 2014This " 'limited judicial duty arises only if the allegations are sufficiently specific; vague or general objections do not trigger the duty to investigate further.' " Johnson at ¶ 68, quoting State v. Carter, 128 Ohio App.3d 419 , 423 No. 13AP-1014 9 (4th Dist.1998). | 2 | 6 |
State v. Pratergreen2 sentences2006In proposition VII, Ketterer further argues that the “trial court erred by failing to hold a hearing when Ketterer announced in court that he wanted to ‘fire’ his lead counsel.” Ketterer relies upon State v. Deal (1969), 17 Ohio St.2d 17 , 46 O.O.2d 154 , 244 N.E.2d 742 , syllabus, wherein this court held that when “an indigent accused questions the effectiveness and adequacy of assigned counsel, * * * it is the duty of the trial judge to inquire into the complaint and make such inquiry a part of the record.” See, also, State v. King (1995), 104 Ohio App.3d 434, 437 , 662 N.E.2d 389 (“inquiry 2006In proposition VII, Ketterer further argues that the “trial court erred by failing to hold a hearing when Ketterer announced in court that he wanted to ‘fire’ his lead counsel.” Ketterer relies upon State v. Deal (1969), 17 Ohio St.2d 17 , 46 O.O.2d 154 , 244 N.E.2d 742 , syllabus, wherein this court held that when “an indigent accused questions the effectiveness and adequacy of assigned counsel, * * * it is the duty of the trial judge to inquire into the complaint and make such inquiry a part of the record.” See, also, State v. King (1995), 104 Ohio App.3d 434, 437 , 662 N.E.2d 389 (“inquiry | 1 | 7 |
State v. Blankenshipgreen1 sentence2011No. 20080, 2001 WL 39600 at *1 (Jan. 17, 2001) (quoting State v. Blankenship, 102 Ohio App. 3d 534, 558 (1995)). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Ohio. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
State v. Johnson
green
2 sentences2022Morgan at ¶ 44 (further citations omitted). {¶ 17} When an indigent defendant questions the effectiveness of the assigned counsel " 'it is the duty of the trial judge to inquire into the complaint and make such inquiry a part of the record.' " State v. Johnson, 112 Ohio St.3d 210 , 2006-Ohio-6404 , ¶ 68, quoting Nos. 21AP-421 and 21AP-422 7 State v. Deal, 17 Ohio St.2d 17 (1969), syllabus. 2014THIRD ASSIGNMENT OF ERROR – DISSATISFACTION WITH COUNSEL {¶ 25} Defendant's third assignment of error asserts that his guilty pleas were not knowingly and voluntarily made, because a manifest injustice occurred "when the court did not enquire [sic] further of the Appellant, subsequent to his expression of dissatisfaction with trial counsel." (Appellant's brief, 14-15.) {¶ 26} " 'Where, during the course of his trial for a serious crime, an indigent accused questions the effectiveness and adequacy of assigned counsel * * *, it is the duty of the trial judge to inquire into the complaint and mak | 5 | 2010–2022 |
State v. Ketterer
green
2 sentences2024The “‘inquiry may be brief and minimal, but it must be made.’” State v. Ketterer, 111 Ohio St.3d 70 , 2006- Ohio-5283, 855 N.E.2d 48 , ¶ 139, quoting State v. King, 104 Ohio App.3d 434, 437 , 662 N.E.2d 389 (4th Dist.1995). 2008"To discharge a court-appointed attorney, the defendant must show a breakdown in the attorney-client relationship of such magnitude as to jeopardize the defendant's right to effective assistance of counsel." State v. Coleman , 37 Ohio St.3d 286 , paragraph four of the syllabus. {¶ 11} Further, the Supreme Court of Ohio held that "when `an indigent accused questions the effectiveness and adequacy of assigned counsel, * * * it is the duty of the trial judge to inquire into the complaint and make such inquiry a part of the record.'" State v. Ketterer , 111 Ohio St.3d 70 , 2006-Ohio-5283 , at ¶ 13 | 2 | 2008–2024 |
State v. Coleman
green
2 sentences2019“The trial judge may then require the trial to proceed with assigned counsel participating if the complaint is not substantiated or is unreasonable.” Id. {¶59} Before a defendant is entitled to the discharge of appointed counsel, “the defendant must show a breakdown in the attorney-client relationship of such magnitude as to jeopardize the defendant’s right to effective assistance of counsel.” State v. Coleman, 37 Ohio St.3d 286 , 525 N.E.2d 792 (1988), paragraph four of the syllabus. 2008"To discharge a court-appointed attorney, the defendant must show a breakdown in the attorney-client relationship of such magnitude as to jeopardize the defendant's right to effective assistance of counsel." State v. Coleman , 37 Ohio St.3d 286 , paragraph four of the syllabus. {¶ 11} Further, the Supreme Court of Ohio held that "when `an indigent accused questions the effectiveness and adequacy of assigned counsel, * * * it is the duty of the trial judge to inquire into the complaint and make such inquiry a part of the record.'" State v. Ketterer , 111 Ohio St.3d 70 , 2006-Ohio-5283 , at ¶ 13 | 2 | 2008–2019 |
State v. Sanders, 2007-L-062 (3-14-2008)
green
1 sentence2014Lake No. 2007-L-062, 2008-Ohio-1126, ¶ 9 . {¶22} When confronted with a request for the appointment of new counsel, “it is the duty of the trial judge to inquire into the complaint and make such inquiry a part of 5 the record. | 1 | 2014–2014 |
Effinger v. Kentucky
green
1 sentence2012Id., citing State v. King, 104 Ohio App.3d 434, 437 , 662 N.E.2d 389 (4th Dist.1995). | 1 | 2012–2012 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.