State v. Culberson

In State v. Culberson, 142 Ohio App.3d 656, 2001 Ohio 3261, 756 N.E.2d 734, the court held that, "when a criminal defendant is collaterally challenging a prior penalty-enhancing conviction on the basis of constitutional infirmity, the only recognized constitutional infirmity is that he or she was denied the fundamental right to be represented by counsel, or the necessary corollary, an invalid waiver of the right to counsel." Id. at 662-663.