State v. Schaumleffel

2026 Ohio 843

• Court: Ohio Court of Appeals
• Decided: March 12, 2026
• Docket: 2025 CA 00058
• Status: Published

Opinion

[Cite as State v. Schaumleffel, 2026-Ohio-843.]

COURT OF APPEALS LICKING COUNTY, OHIO FIFTH APPELLATE DISTRICT

STATE OF OHIO, Case No. 2025 CA 00058

Plaintiff - Appellee Opinion And Judgment Entry

-vs- Appeal from the Licking County Municipal Court, Case No. 24 TRC 08345 JASON SCHAUMLEFFEL, Judgment: Affirmed Defendant – Appellant Date of Judgment Entry: March 12, 2026

BEFORE: Craig R. Baldwin; Robert G. Montgomery; Kevin W. Popham, Judges

APPEARANCES: J. MICHAEL KING, for Plaintiff-Appellee; CHRIS BRIGDON, for Defendant-Appellant.

Montgomery, J.

{¶1} Defendant/Appellant, James Schaumleffel (“Appellant”), states he was

denied his right to effective counsel when the trial court denied his lawyer’s motion to

withdraw during the pendency of the case. We disagree.

STATEMENT OF THE FACTS AND THE CASE

{¶2} Appellant was stopped by Granville police on September 24, 2024, and

charged with one count of OVI in violation of R.C. 4511.19(A)(1)(a) and one count of OVI

in violation of R.C. 4511.19(A)(1)(d). He entered pleas of not guilty to the two counts and

the trial court appointed Attorney Zach Meranda to represent him. Less than two months after his appointment, Attorney Meranda filed a Motion to Withdraw as Counsel of record

citing “irreparable breakdown in the attorney-client communication.” The trial court

granted Attorney Meranda’s motion and appointed Attorney J. Matthew Dawson to

represent Appellant.

{¶3} Attorney Dawson filed a Motion to Suppress with the trial court and an oral

hearing was held. The trial court granted in part and denied in part Appellant’s motion.

{¶4} Following the trial court’s decision on Appellant’s Motion to Suppress,

Appellant sent two ex parte letters to the judge and two requests for continuances. These

letters expressed Appellant’s concerns he had with his lawyer and the case in general.

{¶5} Attorney Dawson filed a Motion to Withdraw as Counsel and the trial court

held an oral hearing on July 10, 2025.

{¶6} The trial court denied Attorney Dawson’s Motion to Withdraw finding that

Appellant was not dissatisfied. Transcript, p. 8.

{¶7} The case proceeded to a jury trial on July 21, 2025, wherein Appellant was

found guilty of OVI in violation of R.C. 4511.19(A)(1)(d). Judgment Entry of Conviction,

p. 1.

ASSIGNMENTS OF ERROR

{¶8} Appellant filed an appeal and asserts the following assignments of error:

{¶9} “I. DENIAL OF COUNSEL’S MOTION TO WITHDRAW AFTER

STATING HE COULD NOT EFFECTIVELY REPRESENT DEFENDANT VIOLATED THE

SIXTH AMENDMENT.” {¶10} “II. COUNSEL WAS INEFFECTIVE AT TRIAL WHERE HE INFORMED

THE COURT HE COULD NOT REPRESENT APPELLANT TO THE BEST OF HIS

ABILITY AND THE COURT FORCED HIM TO PROCEED.”

STANDARD OF REVIEW

{¶11} A trial court's decision on whether to grant motions to withdraw as counsel

is reviewed under an abuse-of-discretion standard. State v. Williams, 99 Ohio St.3d 493,

2003-Ohio-4396, ¶ 135. A trial court’s decision on substitution of counsel is fact specific,

and a reviewing court may reverse only for an abuse of discretion. Id.

ANALYSIS

{¶12} Appellant argues in his first assignment of error that the trial court violated

his rights under the Sixth Amendment when it denied his counsel’s motion to withdraw.

We disagree.

{¶13} In the case at hand, Attorney Dawson filed a motion requesting permission

to withdraw and the court set the matter for an oral hearing. Attorney Dawson referenced

letters Appellant sent to the trial court that criticized his performance at a suppression

hearing. Transcript, p. 2. Attorney Dawson told the court, “I don’t believe, your honor, that

I can represent him after all this has occurred.” Id. Attorney Dawson also stated, “I don’t

think that I can do my best in representation of him because there’s no trust.” Id., p. 5.

Attorney Dawson was also fearful that Appellant would file a grievance against him. Id.

{¶14} When the trial court questioned Appellant, he stated, “It’s not that I don’t

trust Mr. Dawson.” Id., pp. 6, 7. He further stated, “I guess my only complaint was I hadn’t

been able to reach him for several weeks.” Id. Appellant described Attorney Dawson as amazing, compassionate, knew the law and wanted Attorney Dawson to represent him at

his upcoming trial. Id.

{¶15} Appellant argues that when counsel places his inability to proceed on the

record, the trial court must either allow the withdrawal or conduct an inquiry to ensure that

the defendant’s right to counsel is protected. Appellant Brief, p. 5. Appellant cites State v.

Deal, 17 Ohio St.2d 17 (1969), as authority for his argument. The facts of the case in

Deal, are distinguishable from the facts of the case at hand. In Deal, it was the defendant

who raised the issue with the court that he was dissatisfied with his counsel. In the case

at hand, Appellant wrote ex parte letters to the court that criticized Attorney Dawson’s

performance but did not file a motion with the court requesting new counsel.

{¶16} Since it was Attorney Dawson who requested that he be discharged, not

Appellant stating he was dissatisfied, the trial court was not required to inquire into the

circumstances surrounding Attorney Dawson’s request. “The need for an inquiry by the

trial judge into the circumstances surrounding a request to discharge appointed counsel

and appoint substitute counsel will not be recognized where the defendant has not

evidenced his dissatisfaction or wish to remove his appointed counsel.” United States v.

Iles, 906 F.2d 1122, 1131 (6th Cir. 1990).

{¶17} Having reviewed the record, even though not required to do so, this Court

finds that the trial court conducted an inquiry of Attorney Dawson regarding his reasons

for filing his request. The trial court then let Appellant speak to Attorney Dawson’s

concerns. Appellant informed the trial court that he was not dissatisfied and wished for

Attorney Dawson to continue to represent him. {¶18} Appellant has failed to show that his Sixth Amendment rights were violated

or that the trial court abused its discretion when it denied Attorney Dawson’s Motion to

Withdraw.

{¶19} Appellant’s first assignment of error is overruled.

{¶20} Appellant argues in his second assignment of error that Attorney Dawson

was ineffective at trial because he informed the court that he could not represent Appellant

to the best of his ability.

{¶21} As previously stated by this Court under a similar argument, “To obtain a

reversal of a conviction based on ineffective assistance of counsel, the defendant must

prove; (1) that counsel's performance fell below an objective standard of reasonableness,

and (2) that counsel's deficient performance prejudiced the defendant resulting in an

unreliable or fundamentally unfair outcome of the proceeding.” State v. Gray, 2024-Ohio-

347, ¶ 17 (5th Dist.), citing Strickland v. Washington, 466 U.S. 668, 687-688 (1984). “A

defendant's failure to satisfy one prong of the Strickland test negates a court's need to

consider the other.” Id.

{¶22} Appellant’s sole argument is that Attorney Dawson was ineffective because

he expressed concern to the trial court on whether or not he would be able to represent

Appellant to the best of his ability. Appellant asserts, “Once counsel informs the court

that he cannot ethically or competently represent the defendant, the constitutional right to

effective assistance is implicated as a matter of law.” Appellant Brief, p. 7.

{¶23} Appellant has failed to cite a single case that supports his argument.

Appellant has also failed to cite a single circumstance where Attorney Dawson’s

performance fell below an objective standard. {¶24} Appellant has failed to prove that Attorney Dawson’s performance fell below

an objective standard and therefore his second assignment of error is overruled.

CONCLUSION

{¶25} For the reasons stated in our accompanying Opinion, the judgment of the

Licking County Municipal Court is Affirmed.

{¶26} Costs to Appellant.

By: Montgomery, J.

Baldwin, P.J. and

Popham, J. concur.