People of Michigan v. Parrish Lemonte Robinson, 332148

Defendant Robinson was convicted of domestic violence—third offense and unarmed robbery; habitual offender upgraded sentence to 24–180 and 96–360 months, concurrent.
The offenses arose from an attack on the defendant's former girlfriend, Satchell, during which her partial denture was forcibly removed.
Satchell attempted to leave to avoid confrontation; Robinson prevented her departure, assaulted her, and pried out the denture.
Robinson drove away with the denture and discarded it, despite Satchell's inability to replace it; Satchell sustained facial injuries.
Satchell later tracked Robinson to an apartment; he attacked again, and police arrested him after he fled.
Robinson contends ineffective assistance of counsel and improper OV 7 scoring; the Court affirms the convictions and sentences.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Larceny-from-the-person as lesser offense	Robinson asserts larceny from the person was an included offense.	Robinson contends counsel should have requested the instruction.	Not an included offense; no ineffective assistance.
OV 7 scoring for aggravated abuse	Robinson challenges 50-point OV 7 assessment.	OV 7 supported by evidence of sadism and fear-increasing conduct.	OV 7 properly scored at 50 points.

People v LeBlanc, 465 Mich 575 (2002) (mixed question of fact and law; standard of review)
People v Payne, 285 Mich App 181 (2009) (limited review where no Ginther hearing)
People v Trakhtenberg, 493 Mich 38 (2012) (ineffective assistance two-pronged test)
People v Seals, 285 Mich App 1 (2009) (presumed effective assistance; trial strategy respect)
People v Smith-Anthony, 494 Mich 669 (2013) (larceny-from-the-person not automatically included offense)
People v Smith-Anthony, 494 Mich 669 (2013) (robbery scope after 2004 amendments; transactional theory)