State v. Higgins

Ohio Court of Appeals·Decided March 31, 2026·No. 2025CA0046-M·Published·Cited by 1 cases

Opinion

[Cite as State v. Higgins, 2026-Ohio-1133.]

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

STATE OF OHIO C.A. No. 2025CA0046-M

Appellee

v. APPEAL FROM JUDGMENT ENTERED IN THE THOMAS HIGGINS COURT OF COMMON PLEAS COUNTY OF MEDINA, OHIO Appellant CASE No. 2024CR0094

DECISION AND JOURNAL ENTRY

Dated: March 31, 2026

SUTTON, Judge.

{¶1} Defendant-Appellant, Thomas Higgins, appeals the judgment of the Medina

County Court of Common Pleas. This Court affirms.

I.

Relevant Background Information

{¶2} This matter arises from the death of Z.H., due to a fentanyl overdose. After an

investigation, Z.H.’s drug dealer, Mr. Higgins, was charged with one count of corrupting another

with drugs, a violation of R.C. 2925.02(A)(3)/(C)(1), a felony of the second degree.

{¶3} Mr. Higgins pleaded not guilty by reason of insanity and the trial court ordered

competency and sanity evaluations. Upon receiving the results of the competency evaluation, and

learning the Psycho Diagnostic Clinic did not perform a sanity evaluation because Mr. Higgins did

not agree with the not guilty by reason of insanity plea, the trial court found Mr. Higgins competent

to stand trial. Mr. Higgins’ plea of not guilty by reason of insanity was withdrawn and a not guilty 2

plea was entered. Further, after a discussion regarding Mr. Higgins’ counsel’s motion to withdraw

from the case, based upon Mr. Higgins’ desire to represent himself at trial, the trial court continued

the trial date in order for Mr. Higgins to speak with his counsel about the case.

{¶4} Ultimately, the trial court allowed Mr. Higgins’ counsel to withdraw from the case

and, subsequent to a colloquy with the trial court, Mr. Higgins signed a waiver of counsel in open

court. A jury trial commenced and the State called Officer Kyle Haas, the investigating officer at

the crime scene, Dr. Lisa Deranek, the Medina County Coroner, Detective James Allenby, and

Taylor Bright, a public safety intelligence analyst who analyzed data from Z.H.’s cell phone. After

the State’s case-in-chief, Mr. Higgins made a Crim.R. 29 motion which was denied. Mr. Higgins

then testified on his own behalf and called S.M., Z.H.’s neighbor and friend who found Z.H.

unresponsive, as a defense witness. Mr. Higgins rested his case and renewed his Crim.R. 29

motion, which was again denied. The State then called Detective Allenby as a rebuttal witness.

{¶5} The jury returned a verdict of guilty on corrupting another with drugs, and made

a special finding that the controlled substance involved was fentanyl, a Schedule II controlled

substance. The trial court sentenced Mr. Higgins to a mandatory indefinite prison term of a

minimum of five years and a maximum of seven and a half years.

{¶6} Mr. Higgins now appeals raising two assignments of error for our review.

II.

ASSIGNMENT OF ERROR I

THE TRIAL COURT ERRED IN PERMITTING [MR. HIGGINS] TO REPRESENT HIMSELF AND DID NOT COMPLY WITH THE REQUIREMENTS OF STATE V. MARTIN REGARDING SELF- REPRESENTATION.

{¶7} In his first assignment of error, Mr. Higgins argues the trial court erred in permitting

him to represent himself at the jury trial. Specifically, Mr. Higgins argues the case had complex 3

issues, such as cause of death, medical evidence, phone records, and hearsay evidence, and as the

trial proceeded, it was clear Mr. Higgins did not know the rules of evidence or procedure.

{¶8} “The Sixth Amendment guarantees a defendant both the right to counsel and ‘the

right to elect self-representation instead.’” State v. Yeager, 2018-Ohio-574, ¶ 6 (9th Dist.), quoting

State v. Tucker, 2016-Ohio-1353, ¶ 11 (9th Dist.). However, “[a] defendant who wishes to

represent himself must knowingly, voluntarily, and intelligently waive his right to counsel.”

Yeager at ¶ 6, citing State v. Gibson, 45 Ohio St.2d 366 (1976), paragraph one of the syllabus. As

such, “[c]ourts are to indulge every reasonable presumption against the waiver of a fundamental

constitutional right including the right to be represented by counsel.” State v. Trikilis, 2005-Ohio-

4266, ¶ 12 (9th Dist.). Thus, because waiver of counsel may be impactful upon a person's liberties,

“the trial court must make sufficient inquiry to determine whether [the] defendant fully

understands and intelligently relinquishes [his] right.” Trikilis at ¶ 12, quoting State v. Gibson, 45

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

{¶9} In Trikilis at ¶ 13, this Court explained as follows:

In determining the sufficiency of the trial court’s inquiry in the context of a defendant’s waiver of counsel, this Court reviews the totality of the circumstances. 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. While no one factor is dispositive, [this Court] should consider whether the defendant was advised of the nature of the charges and the range of allowable punishments, and, in addition, [this Court] may consider whether the trial court advised the defendant of the possible defenses to the charges and applicable mitigating circumstances. We reaffirm our holding, however, that the trial court's discussion of possible defenses and mitigating circumstances need not be fact specific. In order to avoid placing the trial court in the role of an adversary, a broader discussion of defenses and mitigating circumstances as applicable to the pending charges is sufficient. A court may also consider various other factors, including the defendant's age, education, and legal experience. 4

(Emphasis in original.) (Internal citations omitted.) Therefore, in determining whether the trial

court made sufficient inquiry into whether Mr. Higgins knowingly, voluntarily, and intelligently

relinquished his right to counsel, this Court must look to the record and review the totality of

circumstances. See also State v. Briggs, 2021-Ohio-1980, ¶ 8-10 (9th Dist.).

{¶10} Here, the record reveals the trial court spoke with Mr. Higgins on two occasions

regarding his request to represent himself at trial. After a pre-trial hearing regarding Mr. Higgins’

competency to stand trial and his plea of not guilty by reason of insanity1, Mr. Higgins’ counsel

addressed the trial court regarding Mr. Higgins’ desire to represent himself and have her act as

standby counsel. At that time, Mr. Higgins expressed dissatisfaction with his attorney’s

performance and his desire for self-representation. The trial court asked Mr. Higgins if he went

to law school to which Mr. Higgins responded, “[n]o, but I know--I know- -I know this. I know

this case. I want to represent myself.” The trial court then told Mr. Higgins that “it’s great that

you know the case and you know the facts of the case. Do you know the law that applies?” Mr.

Higgins responded, “[y]es.” The trial court further inquired as to how Mr. Higgins learned the law

and Mr. Higgins responded that he “learned it in prison.” The trial court then warned Mr. Higgins

as follows:

[THE COURT]: Okay. So you’re up against a seasoned prosecutor that’s been to law school, that knows the Rules of Evidence, that knows the Rules of Criminal Procedure, and you think you can adequately defend yourself?

Mr. Higgins responded “[y]es[,]” and went on to say he should not ever have been charged in this

case. The trial court then asked Mr.

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