State of Tennessee v. Ivin Lee Robinson, W2020-00246-CCA-R3-CD

Defendant Ivin Lee Robinson was indicted for first-degree premeditated murder (Count 1), first-degree felony murder (Count 2), and especially aggravated robbery (Count 3).
Before trial the defendant entered an open guilty plea to Count 3 (especially aggravated robbery); trial proceeded on Counts 1 and 2.
Jury convicted Robinson of the lesser-included offense of second-degree murder on both Counts 1 and 2; the convictions were merged and the court imposed a 40-year sentence for second-degree murder (Count 1) and a 40-year sentence for especially aggravated robbery (Count 3), ordered consecutively for an effective 80-year term at 100% release eligibility.
Medical evidence: victim (age 80) suffered multiple .22 gunshot wounds, underwent surgery, was released, then suffered a stroke and died; medical examiner concluded death was "complications and exacerbation of natural chronic disease after multiple gunshot wounds" and ruled the manner homicide.
At sentencing the court applied multiple enhancement factors (including prior criminal history and victim vulnerability) and found grounds for consecutive sentences; defendant filed post-trial motions and appealed.

Issue	State's Argument	Robinson's Argument	Held
Sufficiency — causation for second-degree murder	Evidence (medical examiner + shooting, gun matched to defendant) proves the shooting proximately caused death; issue waived for lack of authority but merits fail.	Victim’s preexisting chronic conditions were the real cause; wounds were healing so defendant did not proximately cause death.	Affirmed: evidence sufficient — defendant unlawfully contributed to death; jury instruction on proximate cause proper.
Lesser-included instructions (reckless & criminally negligent homicide as to felony murder Count 2)	No written specific lesser-included request; trial court properly declined; any error harmless.	Trial evidence supported reckless or criminally negligent homicide instructions.	Waived for failure to make written request; no plain error — relief denied.
Consecutive sentencing	Trial court acted within discretion; record supports at least one statutory ground (extensive criminal record).	80-year consecutive sentence excessive; concurrent sentence adequate.	Affirmed: consecutive sentences upheld under abuse-of-discretion with presumption of reasonableness; extensive criminal record sufficed.
Clerical / merged-judgment forms	N/A	Trial court failed to complete/identify surviving conviction on merged judgment forms.	Remanded for corrected, separate judgment forms and notation of which conviction survives merger.

Jackson v. Virginia, 443 U.S. 307 (establishes standard for appellate sufficiency review)
State v. Farner, 66 S.W.3d 188 (proximate causation for homicide: death is natural and probable result of defendant's conduct)
State v. Pollard, 432 S.W.3d 851 (consecutive-sentencing review: abuse-of-discretion with presumption of reasonableness when trial court states a statutory ground)
State v. Bise, 380 S.W.3d 682 (sentencing principles and appellate review standard reaffirmed)
State v. Fayne, 451 S.W.3d 362 (defendant must file written, specific request to preserve lesser-included-instruction issue)
State v. Berry, 503 S.W.3d 360 (procedures for judgment forms when convictions merge; requirement to note surviving/merged conviction)