Might the states and especially Ohio be required to accept and enforce the 6th and 14th amendment mandates of Gideon vWainwright, 772 U.S. 335, (196), and Argersinger vHarnlin. 07 U.S. 25, (1972), and require the APPOINTMENT OF COUNSEL in Death Penalty Cases for 'ALL "HEARINGS," before a Judicial Officer, even pretrial ones, in order to sustain a valid conviction?

In order to eliminate confusion amongst the states--some states hold--a state court loses jurisdiction if it fails to appoint counsel in a criminal case, following Zerbst v Johnson, 304 U.S. 458 while others, and especially Ohio, hold that a court which fails to appoint counsel does not lose its jurisdiction and holds that Zerbst, only applies to Federal Court proceedings irrespective of tr2ii1es2ie County, 55 4',U -S 191, (2008).

Whether states are required to appoint counsel in death penalty cases for all hearings before a judicial officer to sustain a valid conviction