State v. Robinson, 287 Neb. 799

Robinson was convicted of knowing or intentional child abuse resulting in death and sentenced to life imprisonment.
Robinson sought postconviction relief, and an evidentiary hearing followed the district court's dismissal of his petition.
Robinson alleged trial and appellate counsel were ineffective, including failure to object to voluntariness of statements and to obtain a voluntariness hearing.
The State did not introduce Robinson’s statements at trial; the statements were offered only by Robinson to argue coercion, so a voluntariness hearing was arguably unnecessary.
The district court denied postconviction relief; Robinson appeals challenging the effectiveness of trial and appellate counsel.
The Nebraska Supreme Court affirmed the district court, denying postconviction relief and holding no ineffectiveness by trial or appellate counsel.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether postconviction relief was properly denied for ineffective assistance of counsel	Robinson contends appellate/trial counsel were ineffective under Strickland.	State argues no deficient performance or prejudice occurred.	Denied; no deficient performance or prejudice shown.
Whether trial counsel was ineffective for failing to request a voluntariness hearing or file a motion to suppress	Trial counsel should have challenged voluntariness of statements.	No hearing or suppression motion was necessary since statements were not offered by State.	Not ineffective; no prejudice; hearing/motion unnecessary.
Whether trial counsel was ineffective for not objecting to lack of a voluntariness jury instruction	Failure to object to the voluntariness instruction harmed Robinson.	Record insufficient to determine the original instruction; no prejudice shown.	Not ineffective; no demonstrated prejudice.
Whether appellate counsel was ineffective for not raising trial counsel’s ineffectiveness	Appellate counsel failed to raise issues of trial counsel's ineffectiveness.	Not raising issues had no reversible error given the record.	Not ineffective; appellate strategy affirmed.

Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-pronged test for ineffective assistance of counsel)
State v. Poe, 284 Neb. 750 (Neb. 2012) (standards for ineffective assistance and procedural review)
State v. Watt, 285 Neb. 647 (Neb. 2013) (prejudice analysis in IAC claims)
State v. Seberger, 279 Neb. 576 (Neb. 2010) (requirements of record and review in postconviction)
State v. Watkins, 284 Neb. 742 (Neb. 2012) (guidance on postconviction standards)