Robert Bruce Renfroe v. State, 529 S.W.3d 229

Robert Renfroe pleaded guilty in two causes: aggravated assault (deferred adjudication for 6 years, $1,500 fine) and theft of a firearm (2-year sentence suspended, 5-year community supervision).
The State filed motions to revoke both probations, alleging family-violence assault (wife testified to being struck and hit with a machete), failure to report a new charge to his probation officer, possession of a deadly weapon, and unpaid court costs in the theft case.
Before the revocation hearing, counsel informed the court Renfroe had sustained a stroke 13 months earlier; the court found him competent after Renfroe and counsel represented competency.
At the joint revocation/punishment hearing the court found the alleged violations true, adjudicated guilt on the aggravated-assault plea and revoked supervision in both cases, and sentenced Renfroe to ten years' confinement for aggravated assault and two years' confinement for theft.
Renfroe appealed, arguing (1) the sentences were cruel and unusual under the Eighth Amendment given his stroke-related disabilities and (2) trial counsel was ineffective for failing to obtain medical testimony.
The Eleventh Court of Appeals affirmed, finding preservation and merit problems on the Eighth Amendment claims and no Strickland deficiency or prejudice shown for the ineffective-assistance claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether sentences violated the Eighth Amendment as cruel and unusual	Renfroe: ten- and two-year terms were disproportionate given his stroke and disabilities	State: sentences were within statutory ranges and appropriate given serious family-violence conduct and violations	Court: forfeited preservation for both counts (theft issue forfeited earlier); even if preserved, sentences not grossly disproportionate and therefore not cruel/unusual — affirmed
Whether trial counsel was ineffective for failing to obtain medical/expert testimony	Renfroe: counsel should have sought medical examination/testimony about stroke-related impairments; that evidence likely would have reduced punishment	State: counsel examined Renfroe about his health; no record proof an expert was available or would have helped; failure to call expert not per se deficient	Court: no record evidence counsel’s performance was unreasonable nor that expert testimony would have changed the outcome — Strickland claim fails

Solem v. Helm, 463 U.S. 277 (establishes gross-disproportionality test for Eighth Amendment challenges)
Harmelin v. Michigan, 501 U.S. 957 (discusses proportionality principles outside capital cases)
Strickland v. Washington, 466 U.S. 668 (two-prong standard for ineffective-assistance-of-counsel claims)
Wiggins v. Smith, 539 U.S. 510 (clarifies prejudice and performance prongs under Strickland)
Manuel v. State, 994 S.W.2d 658 (defendant on regular community supervision may only raise certain issues at original imposition of supervision)
Jackson v. State, 680 S.W.2d 809 (appellate deference to trial court's sentencing discretion)