State v. Reese

{¶ 1} We are asked to consider whether strict compliance with R.C. 2945.05 requires a trial court to impose counsel upon a pro se defendant who has already waived his right to counsel and wishes to further waive his right to a jury trial. For the following reasons, we find that strict compliance with R.C. 2945.05 is accomplished by establishing that a pro se defendant had an opportunity to consult with counsel at any time prior to waiving his right to a jury trial, but that actual consultation need not occur, and that appointment of counsel for a pro se defendant is not mandatory under the…