State v. Gilbert

2025 Ohio 4623
CourtOhio Court of Appeals
DecidedOctober 6, 2025
Docket23CA012031
StatusPublished

This text of 2025 Ohio 4623 (State v. Gilbert) 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
State v. Gilbert, 2025 Ohio 4623 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Gilbert, 2025-Ohio-4623.]

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

STATE OF OHIO C.A. No. 23CA012031

Appellee

v. APPEAL FROM JUDGMENT ENTERED IN THE STEVEN GILBERT COURT OF COMMON PLEAS COUNTY OF LORAIN, OHIO Appellant CASE Nos. 21CR105451 21CR105037

DECISION AND JOURNAL ENTRY

Dated: October 6, 2025

FLAGG LANZINGER, Presiding Judge.

{¶1} Defendant-Appellant, Steven Gilbert, appeals from the judgment of the Lorain

County Court of Common Pleas. This Court affirms.

I.

{¶2} The police investigated and identified Mr. Gilbert as a human trafficker. Evidence

showed that he operated a human trafficking ring out of Elyria and surrounding areas for several

years. He was indicted in three separate criminal cases. He resolved one case by plea, and that

case is not before us. In Criminal Case No. 21CR105037, he was indicted on one count of rape,

two counts of having weapons under disability, and one count of promoting prostitution. His rape

charge included two firearm specifications. In Criminal Case No. 21CR105451, he was indicted

on fifty-four counts. That indictment included charges of engaging in a pattern of corrupt activity,

rape, kidnapping, aggravated robbery, trafficking in persons, compelling prostitution, promoting

prostitution, sexual battery, and money laundering. The indictment named nine victims and 2

included firearm specifications and specifications for the forfeiture of property, human trafficking,

committing acts with sexual motivation, and being a sexually violent predator.

{¶3} The trial court consolidated Criminal Case No. 21CR105037 and Criminal Case

No. 21CR105451 for trial. Several of Mr. Gilbert’s charges were dismissed, and he chose to try

his sexual motivation and sexually violent predator specifications to the bench. The remainder of

his charges and specifications were tried to a jury. At the conclusion of trial, he was found guilty

of three counts of engaging in a pattern of corrupt activity, one count of rape, three counts of

kidnapping, one count of aggravated robbery, seven counts of trafficking in persons, five counts

of compelling prostitution, five counts of promoting prostitution, one count of sexual battery, two

counts of money laundering, and a significant number of specifications. The trial court sentenced

him to serve a minimum of 189 years to life in prison. It also classified him as a tier III sexual

offender.

{¶4} Mr. Gilbert now appeals from his convictions and raises eleven assignments of error

for review. For ease of analysis, we consolidate and rearrange several of the assignments of error.

II.

ASSIGNMENT OF ERROR I

TRIAL COURT ERRED WHEN IT DID NOT PERMIT THE APPELLANT TO TERMINATE COUNSEL AND REPRESENT HIMSELF IN VIOLATION OF APPELLANT’S SIXTH AMENDMENT RIGHTS[.]

ASSIGNMENT OF ERROR II

THE TRIAL COURT ERRED IN DENYING APPELLANT-DEFENDANT’S REQUEST TO REPRESENT HIMSELF[.]

{¶5} In his first and second assignments of error, Mr. Gilbert argues the trial court erred

when it refused to let him terminate his appointed attorney and represent himself at trial. For the

following reasons, we reject his argument. 3

{¶6} A criminal defendant has a constitutional right to counsel. U.S. Const., amend. VI;

Ohio Const., art. I, § 10. Yet, no criminal defendant is guaranteed a “meaningful relationship”

with his appointed counsel. Morris v. Slappy, 461 U.S. 1, 14 (1983). “The right to counsel must

be tempered by the public’s right to a prompt, orderly[,] and efficient administration of justice.”

State v. Marinchek, 9 Ohio App.3d 22, 23 (9th Dist. 1983). To secure a discharge of court-

appointed counsel, a defendant must show “good cause, such as a conflict of interest, a complete

breakdown of communication, or an irreconcilable conflict which leads to an apparently unjust

result.” (Internal quotations omitted.) State v. Dawalt, 2007-Ohio-2438, ¶ 15 (9th Dist.), quoting

State v. Alexander, 2006-Ohio-1298, ¶ 15 (10th Dist.). A temporary lack of communication

between a defendant and his attorney is insufficient. State v. Ketterer, 2006-Ohio-5283, ¶ 154.

Likewise, “[d]isagreements between attorney and client over trial strategy do not warrant

substitution of counsel.” State v. Conway, 2006-Ohio-791, ¶ 150. If a criminal defendant fails to

demonstrate good cause for removal, “the trial court may ‘require the trial to proceed with assigned

counsel participating.’” Ketterer at ¶ 150, quoting State v. Deal, 17 Ohio St.2d 17 (1969), syllabus.

{¶7} In addition to having a constitutional right to counsel, “a criminal defendant has a

constitutional right to self-representation.” State v. Perry, 2011-Ohio-2242, ¶ 11 (9th Dist.), citing

Faretta v. California, 422 U.S. 806, 819 (1975). A defendant “may proceed to defend himself

without counsel when he voluntarily, and knowingly and intelligently elects to do so.’” State v.

Schleiger, 2014-Ohio-3970, ¶ 18, quoting State v. Gibson, 45 Ohio St.2d 366 (1976), paragraph

one of the syllabus. “[T]he trial court has to make a sufficient inquiry to determine whether the

defendant fully understands and relinquishes [his right to counsel], which includes advising the

defendant of the dangers and disadvantages of self-representation.” State v. Owens, 2019-Ohio-

2206, ¶ 8 (9th Dist.). “If a trial court denies the right to self-representation when the right has been 4

properly invoked, the denial is per se reversible error.” State v. Neyland, 2014-Ohio-1914, ¶ 71.

Nevertheless, “a strict standard must be applied when determining the adequacy of a criminal

defendant’s invocation of the right to self-representation.” Perry at ¶ 11. “The assertion of the

right . . . must be clear and unequivocal . . . [and] may be denied when circumstances indicate that

the request is made for purposes of delay or manipulation of the trial process.” Neyland at ¶ 72.

{¶8} The record shows Mr. Gilbert had four attorneys throughout the course of the

proceedings. His first attorney, who he retained, withdrew when it became clear that Mr. Gilbert

would not be able to pay his fees. The trial court appointed Mr. Gilbert’s other attorneys. His

second and third attorneys withdrew because he refused to waive his speedy trial rights. The trial

court discussed with him the importance of giving his attorneys time to adequately prepare for

trial, but Mr. Gilbert refused to waive time. His fourth attorney ultimately convinced him to pursue

pretrial motions, thereby tolling his speedy trial time. The trial court appointed the fourth attorney

in December 2021.

{¶9} The trial court originally scheduled the first of Mr. Gilbert’s three criminal cases

for trial in mid-June 2022. The morning of trial, his attorney informed the court that Mr. Gilbert

did not want to go to trial and wanted a new attorney. The attorney indicated that, just two days

earlier, he had spoken with Mr. Gilbert about the case and a plea offer from the State. At that time,

Mr. Gilbert had not expressed any issue with his representation. The attorney learned of Mr.

Gilbert’s alleged dissatisfaction with his representation on the morning of trial. The attorney stated

that, if Mr. Gilbert wanted to reject the State’s offer, he was fully prepared to litigate his case. Mr.

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Related

Drope v. Missouri
420 U.S. 162 (Supreme Court, 1975)
Faretta v. California
422 U.S. 806 (Supreme Court, 1975)
Morris v. Slappy
461 U.S. 1 (Supreme Court, 1983)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Kumho Tire Co. v. Carmichael
526 U.S. 137 (Supreme Court, 1999)
Frank M. Gaito, C-7482 v. Joseph R. Brierley
485 F.2d 86 (Third Circuit, 1973)
State v. Hunter
2011 Ohio 6524 (Ohio Supreme Court, 2011)
State v. Neyland (Slip Opinion)
2014 Ohio 1914 (Ohio Supreme Court, 2014)
State v. Smith
2013 Ohio 3868 (Ohio Court of Appeals, 2013)
State v. Pleban
2011 Ohio 3254 (Ohio Court of Appeals, 2011)
State v. Perry
2011 Ohio 2242 (Ohio Court of Appeals, 2011)
State v. Schleiger (Slip Opinion)
2014 Ohio 3970 (Ohio Supreme Court, 2014)
Sliwinski v. St. Edwards
2014 Ohio 4655 (Ohio Court of Appeals, 2014)
State v. Tucker
2016 Ohio 1354 (Ohio Court of Appeals, 2016)
State v. Moon
337 N.E.2d 794 (Ohio Court of Appeals, 1975)
State v. Patel, 24024 (9-17-2008)
2008 Ohio 4692 (Ohio Court of Appeals, 2008)
State v. Guenther, Unpublished Decision (2-22-2006)
2006 Ohio 767 (Ohio Court of Appeals, 2006)
State v. Rubenstein
531 N.E.2d 732 (Ohio Court of Appeals, 1987)
State v. Knight, Unpublished Decision (3-17-2004)
2004 Ohio 1227 (Ohio Court of Appeals, 2004)
State v. Dawalt, 06ca0059-M (5-21-2007)
2007 Ohio 2438 (Ohio Court of Appeals, 2007)

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