Hudson v. Ravida

CourtOhio Court of Appeals
DecidedMay 27, 2026
Docket31285
StatusPublished

This text of Hudson v. Ravida (Hudson v. Ravida) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hudson v. Ravida, (Ohio Ct. App. 2026).

Opinion

[Cite as Hudson v. Ravida, 2026-Ohio-1947.]

STATE OF OHIO ) IN THE COURT OF APPEALS )ss: NINTH JUDICIAL DISTRICT COUNTY OF SUMMIT )

CITY OF HUDSON C.A. No. 31285

Appellee

v. APPEAL FROM JUDGMENT ENTERED IN THE ANTHONY RAVIDA STOW MUNICIPAL COURT COUNTY OF SUMMIT, OHIO Appellant CASE No. 2024 CRB 00301

DECISION AND JOURNAL ENTRY

Dated: May 27, 2026

CARR, Presiding Judge.

{¶1} Appellant, Anthony Ravida, appeals the judgment of the Stow Municipal Court.

This Court affirms in part, reverses in part, and remands.

I.

{¶2} The instant controversy stems from the manner in which Ravida erected a fence on

his residential property in Hudson. While it is possible for Hudson residents to obtain

administrative approval of their plans to build a fence, Ravida was required to appear before the

Architectural and Historic Board of Review (AHBR) because the plans for his fence conflicted

with the City’s architectural design standards. The City issued Ravida a zoning permit with a site

plan after Ravida reached an agreement with the AHBR on several modifications to his plans.

{¶3} After Ravida erected his fence, the City conducted an inspection and determined

that he had failed to comply with the conditions upon which the zoning permit was issued. The

City filed a complaint charging Ravida with failing to comply with the conditions of a permit 2

approved by the AHBR, a misdemeanor of the third degree. Ravida pleaded not guilty to the

charge at arraignment. The matter proceeded to a bench trial where Ravida represented himself.

The trial court found Ravida guilty. The trial court imposed a $500 fine and a 30-day prison

sentence upon Ravida. The trial court suspended 20 days of the jail sentence on the condition that

Ravida remedy the zoning permit violations within 30 days. Ravida filed a notice of appeal. This

Court dismissed the attempted appeal on the basis that the trial court’s sentencing entry did not

constitute a final, appealable order. On remand, the trial court imposed a $500 fine with a 30-day

jail sentence, all of which was suspended on the condition that Ravida obey all laws for one year

and “place the subject fence in a proper location and remove the wire mesh.”

{¶4} On appeal, Ravida raises four assignments of error. This Court rearranges Ravida’s

assignments of error to facilitate review.

II.

ASSIGNMENT OF ERROR II

THE COURT DID NOT SECURE A KNOWING, INTELLIGENT, AND VOLUNTARY WAIVER OF RAVIDA’S RIGHT TO COUNSEL.

{¶5} In his second assignment of error, Ravida argues that the trial court did not secure

a knowing, intelligent, and voluntary waiver of his right to counsel. This Court agrees.

{¶6} Ravida argues that the trial court failed to secure a proper waiver of counsel in this

case, in violation of his constitutional right to counsel as well as Crim.R. 44(B). Crim.R. 44(B)

states, “[w]here a defendant charged with a petty offense is unable to obtain counsel, the court may

assign counsel to represent the defendant. When a defendant charged with a petty offense is unable

to obtain counsel, no sentence of confinement may be imposed upon the defendant, unless after

being fully advised by the court, the defendant knowingly, intelligently, and voluntarily waives

assignment of counsel.” 3

{¶7} The United States Supreme Court has held that a defendant cannot be imprisoned

for any type of offense unless he was represented by counsel at trial or he made a knowing and

intelligent waiver of his right to counsel. Argersinger v. Hamlin, 407 U.S. 25, 37 (1972). With

respect to cases tried in Ohio courts, this Court has recognized that the right to counsel “extends

to misdemeanor cases that could result in the imposition of a jail sentence.” (Internal quotations

and citations omitted.) State v. Knight, 2012-Ohio-5816, ¶ 14 (9th Dist.); see also State v.

Frederick, 2020-Ohio-714, ¶ 8 (9th Dist.). This right to counsel applies to all critical stages of

criminal proceedings. State v. Schleiger, 2014-Ohio-3970, ¶ 13. “In order to establish an effective

waiver of [the] right to counsel, the trial court must make sufficient inquiry to determine whether

[the] defendant fully understands and intelligently relinquishes that right.” State v. Gibson, 45

Ohio St.2d 366 (1976), paragraph two of the syllabus.

{¶8} The trial court “must investigate [a defendant’s request for self-representation] as

long and as thoroughly as the circumstances of the case before him demand[.]” State v. Obermiller,

2016-Ohio-1594, ¶ 42, quoting Von Moltke v. Gillies, 332 U.S. 708, 723-724 (1948). This Court

reviews the totality of the circumstances when determining whether the trial court conducted a

sufficient inquiry into a defendant’s decision to waive the right to counsel. State v. Briggs, 2021-

Ohio-1980, ¶ 10 (9th Dist.). “In verifying that a waiver of counsel is made knowingly, voluntarily,

and intelligently, a trial court should determine whether the defendant was advised of the dangers

and disadvantages of self[-]representation.” State v. Trikilis, 2005-Ohio-4266, ¶ 13 (9th Dist.).

“While no one factor is dispositive, the trial court should consider whether the defendant was

advised of the nature of the charges and the range of allowable punishments, and, in addition, may

consider whether the trial court advised the defendant of the possible defenses to the charges and

applicable mitigating circumstances.” Id., citing Gibson at 377, citing Von Moltke at 724. The 4

trial court should also address “all other facts essential to a broad understanding of the whole

matter.” Von Moltke at 724. “[T]he information a defendant must possess in order to make an

intelligent election will depend on a range of case-specific factors, including the defendant’s

education or sophistication, the complex or easily grasped nature of the charge, and the stage of

the proceeding.” State v. Gilcreast, 2020-Ohio-1207, ¶ 9 (9th Dist.), citing Schleiger at ¶ 19.

{¶9} At arraignment, Ravida entered a plea of not guilty and declined the appointment

of counsel on his behalf. The matter ultimately proceeded to a bench trial. A review of the

transcript reveals that, prior to the commencement of trial, the trial court engaged in the following

exchange with Ravida:

THE COURT: All right. Generally it doesn’t make sense to not have representation in the trial. Do you understand that?

THE DEFENDANT: Yes.

THE COURT: The reason is, I’m not allowed to help you.

THE DEFENDANT: Right.

THE COURT: At the same time, I’ll try to explain things if something necessary comes up. If you could not afford an attorney, one would be appointed to represent you because this is the kind of case that has potential jail time.

THE DEFENDANT: Okay.

THE COURT: Do you understand that?

THE DEFENDANT: Yes, sir.

THE COURT: Do you wish to proceed representing yourself after hearing what I’ve just said to you?

THE DEFENDANT: Yes. 5

{¶10} The record here supports Ravida’s contention that the trial court failed to secure a

knowing, intelligent, and voluntary waiver of his right to counsel. Putting forth a defense in this

case required Ravida to understand how a third-degree misdemeanor charge related to Hudson’s

regulatory zoning scheme.

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Related

Von Moltke v. Gillies
332 U.S. 708 (Supreme Court, 1948)
Argersinger v. Hamlin
407 U.S. 25 (Supreme Court, 1972)
State v. Knight
2012 Ohio 5816 (Ohio Court of Appeals, 2012)
State v. Schleiger (Slip Opinion)
2014 Ohio 3970 (Ohio Supreme Court, 2014)
State v. Lindow
2016 Ohio 913 (Ohio Court of Appeals, 2016)
State v. Obermiller (Slip Opinion)
2016 Ohio 1594 (Ohio Supreme Court, 2016)
State v. Trikilis, Unpublished Decision (8-17-2005)
2005 Ohio 4266 (Ohio Court of Appeals, 2005)
State v. Byall
2019 Ohio 3132 (Ohio Court of Appeals, 2019)
State v. Frederick
2020 Ohio 714 (Ohio Court of Appeals, 2020)
State v. Gilcreast
2020 Ohio 1207 (Ohio Court of Appeals, 2020)
Skycasters, L.L.C. v. Kister
2021 Ohio 4154 (Ohio Court of Appeals, 2021)
State v. Gibson
345 N.E.2d 399 (Ohio Supreme Court, 1976)
State v. Jenks
574 N.E.2d 492 (Ohio Supreme Court, 1991)
State v. Thompkins
678 N.E.2d 541 (Ohio Supreme Court, 1997)
State v. Arcuri
2024 Ohio 4825 (Ohio Court of Appeals, 2024)

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Bluebook (online)
Hudson v. Ravida, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hudson-v-ravida-ohioctapp-2026.