State v. Robinson, 275 So. 3d 938

In Sept. 2011 Robinson entered a casino armed and shot at three people, wounding one; he was charged with three counts of attempted second‑degree murder.
A three‑member sanity commission evaluated Robinson and issued reports finding him competent; the defendant agreed to submit competency on the reports.
On Aug. 18, 2014 Robinson withdrew an insanity plea and pled guilty to three counts of attempted second‑degree murder after a Boykin colloquy; he was sentenced on Mar. 5, 2015 to concurrent 50‑year hard labor terms.
Robinson later moved to vacate his pleas and/or modify sentences, alleging incompetence at plea/sentencing and ineffective assistance of prior counsel; a defense expert opined Robinson had bipolar disorder with psychotic features and was incompetent when he pleaded and was sentenced.
The trial court denied the motion to vacate (finding the pleas knowing, voluntary, and Robinson competent) but ordered a new evaluation; based on the subsequent report the court resentenced Robinson on Apr. 4, 2018 to concurrent 40‑year hard labor terms.
On appeal the court affirmed convictions and the 40‑year sentences, rejecting challenges to competency determination, plea withdrawal, ineffective assistance (as premature for appeal), and concluding excessive‑sentence claims were procedurally barred for failing to renew an Art. 881.1 motion after resentencing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Competency procedure before accepting plea	State: proper sanity commission appointed; defendant submitted competency on reports	Robinson: court should have made explicit competency determination before accepting guilty plea	Held: procedures under La. Code Crim. P. arts. 641 et seq. satisfied; defendant effectively submitted issue and court properly relied on reports and observations; no due process violation
Merits of competency / motion to withdraw plea	State: commission reports and court observations show competency; plea knowing and voluntary	Robinson: defense expert says bipolar with psychosis; not competent at plea/sentencing; plea should be vacated	Held: trial court’s competency determination not an abuse of discretion; guilty plea was knowing and voluntary; motion to vacate denied
Ineffective assistance of counsel	Robinson: prior counsel failed to investigate defenses and mental status, so plea uninformed	State: record does not definitively resolve Strickland claims on direct appeal	Held: claims more properly raised in post‑conviction relief; not resolved on appeal
Excessive sentence / preservation	Robinson: 40‑year terms are excessive	State: defendant failed to file renewed Art. 881.1 motion after resentencing, so appellate review waived	Held: sentences not reviewed on merits due to procedural bar (no preserved motion to reconsider); convictions and sentences affirmed

State v. Carmouche, 872 So.2d 1020 (La. 2004) (competency procedures and due process standards)
State v. Bonicard, 752 So.2d 184 (La. App. 4th Cir. 1999) (setting trial date can indicate court found defendant competent)
Boykin v. Alabama, 395 U.S. 238 (U.S. 1969) (requirements for a knowing and voluntary guilty plea)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two‑part ineffective assistance standard)
Hill v. Lockhart, 474 U.S. 52 (U.S. 1985) (prejudice inquiry for counsel error in plea context)
State v. Bennett, 345 So.2d 1129 (La. 1977) (factors for competency—understanding proceedings and assisting counsel)
State v. Odenbaugh, 82 So.3d 215 (La. 2011) (competency definition and standards)
State v. Brooks, 541 So.2d 801 (La. 1989) (deference to trial court competency findings)
State v. White, 517 So.2d 461 (La. App. 1st Cir. 1987) (Boykin colloquy and plea validity)