Janette Ebony Robinson v. State of Tennessee, M2016-00058-CCA-R3-PC

Background

Robinson was indicted in Davidson County for multiple counts related to severe injuries to her 3-year-old daughter (2011); she pleaded guilty to two counts of aggravated child abuse on March 7, 2014, in exchange for an effective 25-year sentence at 100% and dismissal of remaining counts.
At plea hearing the prosecutor recited medical and investigatory facts (arm fracture, later liver/pancreas laceration, head injuries, healing rib fracture, patterned whip-like bruises) and conflicting statements by Robinson; no other persons were identified as responsible for certain injuries.
Shortly after pleading guilty Robinson sent a handwritten letter seeking to withdraw her pleas, claiming counsel failed to explain the plea and that she was off her psychiatric medication and therefore not competent at the plea hearing.
Trial court denied motion to withdraw; this court affirmed on direct appeal, finding Robinson had testified at the plea hearing she was taking medication, understood the plea, and was satisfied with counsel.
Robinson sought post-conviction relief alleging ineffective assistance (poor investigation, inadequate communication, failure to obtain competency evaluation, failure to explain plea) and that pleas were unknowing/ involuntary; an evidentiary hearing followed where counsel and Robinson gave conflicting testimony about communications, investigation, and Robinson’s medication status.
The post-conviction court credited counsel, found no deficient performance or involuntary plea (noting prior motion-to-withdraw litigation), and denied relief; this court affirmed the denial.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel provided ineffective assistance (investigation/communication)	Robinson: counsel visited infrequently, failed to produce discovery, did not interview witnesses or pursue defense blaming father, and pressured plea	State/counsel: multiple jail visits with investigator, reviewed discovery and mental-eval, investigated witnesses, urged plea as reasonable	Denied — court credited counsel; performance not shown deficient nor prejudicial
Whether counsel failed to seek competency/mental-health evaluation affecting plea	Robinson: counsel should have had competency evaluation because she was off meds and mentally ill	Counsel: forensic evaluation had been performed (Vanderbilt) and found competence; counsel discussed mental health with petitioner	Denied — competency addressed earlier; plea voluntariness not undermined
Whether Robinson’s guilty pleas were knowing and voluntary	Robinson: was off medication, did not understand plea, was coerced/insufficiently explained the plea	State/counsel: at plea hearing Robinson affirmed she was taking meds, understood rights, and was satisfied with counsel; prior direct appeal rejected withdrawal	Denied — plea was knowingly and voluntarily entered; law-of-the-case applied
Whether Robinson would have gone to trial but for counsel’s errors (prejudice)	Robinson: would have told truth at trial and implicated father; would have insisted on trial	State/counsel: petitioner gave multiple versions, produced no reliable witnesses, father had partial alibi and no admissions; counsel reasonably advised plea	Denied — no reasonable probability outcome different; Hill/Strickland standard unmet

Key Cases Cited

Strickland v. Washington, 466 U.S. 668 (1984) (two-prong standard for ineffective assistance: deficient performance and prejudice)
Hill v. Lockhart, 474 U.S. 52 (1985) (prejudice inquiry in guilty-plea context requires showing likely would have gone to trial)
Boykin v. Alabama, 395 U.S. 238 (1969) (plea must be voluntary and knowing; court must assure defendant understands consequences)
Tidwell v. State, 922 S.W.2d 497 (Tenn. 1996) (post-conviction factual findings entitled to deference)
Henley v. State, 960 S.W.2d 572 (Tenn. 1997) (appellate courts should not reweigh factual issues from trial court)
Ruff v. State, 978 S.W.2d 95 (Tenn. 1998) (de novo review for legal application to facts)
Fields v. State, 40 S.W.3d 450 (Tenn. 2001) (ineffective-assistance claims present mixed questions; give deference to trial court’s factual findings)
Goad v. State, 938 S.W.2d 363 (Tenn. 1996) (objective reasonableness standard for counsel’s performance)
Blankenship v. State, 858 S.W.2d 897 (Tenn. 1993) (factors to assess voluntariness and intelligence of plea)
Pettus v. State, 986 S.W.2d 540 (Tenn. 1999) (trial court must ensure defendant aware of significant consequences of plea)
State v. Willis, 496 S.W.3d 653 (Tenn. 2016) (law-of-the-case doctrine binds later appeals when facts substantially same)