Ronald Robinson v. State, 01-14-00656-CR

Ronald Robinson was convicted of capital murder (jury assessed life) for the 1991 shooting death of Jimmy Sims and appealed. Trial court certified appeal.
Facts: Robinson had motive—his wife had a long-term affair with Sims; Robinson repeatedly threatened Sims and appeared outside his home at night before the killing.
Key witnesses: Bob Mason (later convicted for the murder), Javier Martinez (drove perpetrators to and from the scene; treated as accomplice witness), and Greg Fuentes (knew Mason, witnessed Mason tell Robinson “I took care of your problem. He’s dead.”).
Martinez testified he transported Mason and another man to the scene and drove them away after the shooting; the jury was instructed that Martinez was an accomplice and required corroboration.
Defense counsel elicited evidence (and did not object to introduction) that Mason was convicted of capital murder; defense argued Mason was the primary, untrustworthy source and used his conviction to undermine Mason’s credibility.
Appellate issues focused on: (1) ineffective assistance for allowing Mason’s conviction evidence; and (2) whether the trial court erred by failing to sua sponte instruct the jury that Fuentes was an accomplice witness.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Robinson)	Held
1. Ineffective assistance for counsel introducing Mason’s conviction	Counsel’s admission was trial strategy to attack Mason’s credibility; strong presumption of reasonableness	Admission prejudiced Robinson; counsel was deficient and result might differ absent the evidence	Court rejects Robinson’s claim: counsel’s conduct was plausible strategy and Robinson failed Strickland prejudice showing
2. Trial court duty to give accomplice-witness instruction for Fuentes sua sponte	Fuentes was not an accomplice as a matter of law or fact; his acts did not affirmatively promote the murder	Failure to instruct on Fuentes as accomplice harmed fairness of trial and required reversal	Court rejects; no accomplice instruction required for Fuentes, and even if error, corroborating non-accomplice evidence precludes egregious harm

Strickland v. Washington, 466 U.S. 668 (1984) (two-prong standard for ineffective assistance: performance and prejudice)
Ex parte Imoudu, 284 S.W.3d 886 (Tex. Crim. App. 2009) (ineffective assistance framework and deference to trial strategy)
Blake v. State, 971 S.W.2d 451 (Tex. Crim. App. 1998) (definition and treatment of accomplice witness as matter of law vs. fact)
Almanza v. State, 686 S.W.2d 157 (Tex. Crim. App. 1984) (harmless-error framework for jury-charge error)
Paredes v. State, 129 S.W.3d 530 (Tex. Crim. App. 2004) (accomplice status requires affirmative act promoting the offense)
Ex parte Martinez, 330 S.W.3d 891 (Tex. Crim. App. 2011) (prejudice analysis under Strickland in light of the totality of evidence)