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

QUESTION(S) PRESENTED 1) Might the states and especially Ohio be required to accept and enforce the 6th and 14th amendment mandates of Gideon v_ Wainwright, 772 U.S. 335, (196), and Arger° Singer _v_ Hamlin. 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? : ‘ 2) 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 Rothgery v Gillespie County, 5% U.S. 191, (2008). --IT-|. ‘ fe