Robinson v. State, 2016 Ark. 211

Dion Dashonne Robinson was charged with four counts of aggravated robbery (class Y), four counts of felony theft (class B), and one misdemeanor possession; the information was later amended to include firearm enhancements.
At a Feb 28, 2013 status hearing Robinson, represented by counsel Jimmy Morris, was told of a State plea offer which he rejected; the State withdrew that offer and later added a firearms enhancement.
On June 5, 2014, Robinson accepted a plea of guilty to eight felonies and one misdemeanor in exchange for eight concurrent twenty-year sentences (no firearm enhancements); judgment entered June 16, 2014.
Robinson filed a timely Rule 37 postconviction petition alleging ineffective assistance of trial counsel for (1) failing to properly advise him about the consequences of rejecting an earlier (alleged ten-year) offer and (2) failing to pursue plea negotiations or trade information about accomplices for a better deal.
The State moved to dismiss, arguing Robinson’s factual allegations were false or insufficient, counsel was not deficient, and Robinson suffered no prejudice because he accepted the State’s available twenty-year concurrent offer.
The circuit court denied relief without an evidentiary hearing, finding the files conclusively showed no error or prejudice; Robinson appealed and the Arkansas Supreme Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel was ineffective for failing to advise Robinson about the implications of rejecting an earlier ten‑year offer	Robinson: Counsel did not properly inform him that rejecting the initial offer would lead to harsher future offers; had he known he would not have rejected it	State: Robinson was informed of the offer and voluntarily rejected it; counsel need not be omniscient about future plea posture	Court: No—record shows Robinson was advised and rejected the offer; no deficient performance or prejudice shown
Whether counsel was ineffective for failing to exchange information about accomplices for a better plea	Robinson: Counsel should have traded accomplice information to secure a lighter sentence	State: The State had no interest in such information; counsel’s failure to pursue it was not deficient	Court: No—Robinson failed to show the State’s interest or resulting prejudice; claim insufficient to require an evidentiary hearing

Strickland v. Washington, 466 U.S. 668 (ineffective-assistance two-part test)
Tollett v. Henderson, 411 U.S. 258 (competence standard for counsel in guilty-plea context)
Scott v. State, 406 S.W.3d 1 (Ark. 2012) (prejudice prong requires reasonable probability petitioner would have insisted on trial)
Adams v. State, 427 S.W.3d 63 (Ark. 2013) (standard of review for Rule 37 denials)