State v. Martin

{¶ 1} We are asked to decide what constitutes sufficient waiver of the accused’s right to counsel under the Sixth Amendment of the United States Constitution and Section 10, Article I of the Ohio Constitution. In this case, because we find that the accused essentially proceeded pro se, without being sufficiently warned of the dangers of self-representation and without properly waiving his right to counsel, we affirm the judgment of the court of appeals.

{¶ 2} In 2001, the Cuyahoga County Grand Jury returned a ten-count indictment against defendant-appellee, Kyle Martin, charging him with…