ROBINSON v. STATE OF MAINE, 1:24-cv-00334

Kevin Robinson was convicted in Maine state court of two counts of aggravated drug trafficking based on multiple controlled buys in 2017.
The convictions were partially based on Robinson’s prior felony drug conviction, confirmed through a bifurcated process during trial.
Robinson directly appealed, challenging the court's use of the word 'aggravated' while describing charges and the manner of jury polling; the Law Court affirmed the convictions.
Robinson sought state postconviction relief, which was denied after an evidentiary hearing; subsequent discretionary appeals were denied or dismissed as untimely.
Robinson then filed a federal habeas petition under 28 U.S.C. § 2254, alleging ineffective assistance of counsel and trial court errors, including improper jury polling.

Issue	Robinson's Argument	State's Argument	Held
Trial court's use of 'aggravated' & prior conviction	Use of the term prejudiced the jury against him	Any error was harmless; record did not show prejudice	No reversible error; not fundamentally unfair
Ineffective assistance concerning prior conviction	Counsel failed to explain stipulation/bifurcation; prejudiced defense	Counsel acted reasonably; no prejudice	Counsel not ineffective; no prejudice
Inadequate pretrial investigation	Counsel did not sufficiently probe mental health or discovery	Counsel reasonably investigated	No deficient performance or prejudice
Jury polling conduct	Polling format/timing violated rights	Process was proper; not a constitutional violation	No constitutional right to specific polling; no error
Ineffective assistance by appellate/postconviction counsel	Appellate/postconviction counsel failed to press viable claims	No entitlement to counsel post-appeal	No basis for habeas relief; not unconstitutional

Baldwin v. Reese, 541 U.S. 27 (requiring fair presentation of federal claims in state court)
Coleman v. Thompson, 501 U.S. 722 (federal habeas review barred by adequate and independent state procedural rules unless cause/prejudice or miscarriage of justice shown)
Martinez v. Ryan, 566 U.S. 1 (recognizing narrow exception to procedural default for initial collateral-review proceedings)
Strickland v. Washington, 466 U.S. 668 (establishing two-prong test for ineffective assistance of counsel)
Pennsylvania v. Finley, 481 U.S. 551 (no constitutional right to counsel in collateral postconviction proceedings)
Harrington v. Richter, 562 U.S. 86 (federal courts must defer to reasonable state-court decisions on merits)