State v. Daily

(¶ 16} I write separately to emphasize that the reversal is required due to the state of the record.

{¶ 17} Gonzalez-Lopez, 548 U.S. 140, 126 S.Ct. 2557, 165 L.Ed.2d 409, held that a court’s erroneous decision to remove retained counsel in a criminal case is not subject to a harmless-error analysis; that is, the defendant need not object, *245allege that his subsequently appointed counsel was ineffective, or show that he would not have pleaded but for the removal of his retained attorney. Similarly, it cannot be claimed that he waived any error by entering a plea, especially a no-contest plea. To…