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State v. Robinson
2012 Ohio 5506
Ohio Ct. App.
2012
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Background

  • Robinson was convicted of murder, felonious assault, and aggravated assault arising from a October 17, 2010 incident at Earth Nightclub parking lot.
  • Nord, Robinson's girlfriend, testified about Robinson's knife possession and threats; she had pleaded guilty to obstructing justice.
  • Ghee died from a stab wound; Dorian Williams was stabbed with injuries requiring 46 stitches.
  • Evidence included witness testimony, security video, and blood/on-scene blood analysis linking a knife to the incident.
  • Trial court merged murder with felonious assault for sentencing; Robinson received 15 years to life plus a one-year term for aggravated assault, with restitution.
  • The court remanded for nunc pro tunc correction to postrelease control imposition.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Was the conviction supported by sufficient and weight of the evidence? State argues evidence showed knife use and injuries satisfy elements. Robinson argues insufficiency/weight due to disputed weapon and causation. Sufficient evidence supported knife use; not against weight.
Did the trial court abuse by admitting victim-character evidence? State contends background evidence admissible as context. Robinson contends undue prejudice from victim portrayal. No abuse; background, not propensity, admissible under standards.
Was there ineffective assistance of counsel? State asserts no deficient performance prejudicing defense. Robinson claims Strickland prejudice. No reversible error; issues already resolved as meritless.
Was postrelease control properly advised in sentencing? State concedes journal entry omitted postrelease control language. Robinson insists proper imposition was required at sentencing. Remand for nunc pro tunc postrelease-control entry.

Key Cases Cited

  • State v. Thompkins, 78 Ohio St.3d 380 (1997) (standard for evaluation of sufficiency of evidence)
  • State v. Jenks, 61 Ohio St.3d 259 (1991) (jury rationality in circumstantial evidence review)
  • State v. Mabry, 5 Ohio App.3d 13 (1982) (aggravated assault under extreme emotional stress)
  • State v. Paythress, 8th Dist. No. 91554 (2009) (knife evidence sufficiency where weapon not recovered)
  • State v. Martin, 20 Ohio App.3d 172 (1st Dist. 1983) (thirteenth juror weight-of-the-evidence review)
  • State v. Brodbeck, 2008-Ohio-6961 (10th Dist. 2008) (background evidence admissible to identify victim)
  • State v. Johnson, 112 Ohio St.3d 210 (2006) (victim background admissibility in homicide cases)
  • State v. Henderson, 39 Ohio St.3d 24 (1988) (ineffective assistance standard)
  • State v. Qualls, 2012-Ohio-1111 (Supreme Court of Ohio, 2012) (nunc pro tunc postrelease-control entry requirement)
Read the full case

Case Details

Case Name: State v. Robinson
Court Name: Ohio Court of Appeals
Date Published: Nov 29, 2012
Citation: 2012 Ohio 5506
Docket Number: 97951
Court Abbreviation: Ohio Ct. App.