State v. Robinson, 81 So. 3d 90

Robinson was charged with two counts each of armed robbery and attempted armed robbery in connection with two May 11, 2008 incidents in New Orleans.
He was convicted at trial of armed robbery and attempted armed robbery; the district court later adjudicated him a second felony offender and sentenced 198 years (armed robbery) and 49.5 years (attempted armed robbery) to be served consecutively.
The convictions were based on identifications by the victims from a six-person lineup and trial testimony describing a disguise used by the robber.
The defense offered an alibi defense stating Robinson was with a former girlfriend at the relevant apartment during the robberies.
Robinson’s multiple offender adjudication and sentences were challenged on appeal, including arguments of misidentification, ineffective assistance of counsel, and excessiveness.
The court affirmed the convictions and sentences, denying the post-judgment relief requested by Robinson.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Misidentification sufficiency	Robinson argues the State failed to negate misidentification.	Robinson contends identifications were unreliable under Manson v. Brathwaite.	Identifications deemed reliable; sufficient evidence supports conviction.
Ineffective assistance of counsel	Robinson claims counsel failed to preserve cleansing-period issue.	State argues issue not preserved but reviewable on appeal.	No reversible error; cleansing-period elapsed; no prejudice shown.
Excessiveness and consecutive sentences	Robinson contends sentences are excessive and should run concurrent.	Court acted within discretion, citing Article 894.1 and aggravating factors.	Consecutive sentences affirmed; not constitutionally excessive.

Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (sufficiency review standard: rational finder could convict)
State v. Brown, 907 So.2d 1 (La. 2005) (Jackson sufficiency framework applied in Louisiana)
State v. Neal, 796 So.2d 649 (La. 2001) (Jackson standard applied to identity evidence)
State v. Captville, 448 So.2d 676 (La. 1984) (explains Jackson standard and admissibility in identity cases)
Manson v. Brathwaite, 432 U.S. 98 (U.S. 1977) (five-factor test for eyewitness identification reliability)
State v. Jones, 822 So.2d 205 (La. App. 4th Cir. 2002) (applies Manson factors to eyewitness identifications)
State v. Sterling, 684 So.2d 74 (La. App. 4th Cir. 1996) (delay between crime and lineup not per se unreliable)
State v. McCray, 679 So.2d 543 (La. App. 2d Cir. 1996) (principal case on consecutive sentencing for separate incidents)