State v. Bock

In State v. Bock (1986), 28 Ohio St.3d 108, 28 Ohio B. 207, 502 N.E.2d 1016, the court held that "the failure to hold a competency hearing is harmless error where the defendant proceeds to participate in trial, offers his own testimony in defense and is subject to cross-examination, and the record fails to reveal sufficient indicia of incompetency." Id. at paragraph one of the syllabus. In Bock, notably, the defendant was never found incompetent prior to the trial court proceeding to trial, and the court specifically emphasized that there was no indicia of incompetency.