State v. Robinson

Summary

The Ohio Twelfth District Court of Appeals affirmed Robbi Davon Robinson's convictions for aggravated murder, aggravated arson, and felonious assault, as well as his sentence of life imprisonment without parole plus an indefinite prison term. The court rejected Robinson's ineffective-assistance claims concerning speedy-trial waivers and cross-examination. It also held that the trial court provided the required Reagan Tokes notifications for the felonious-assault sentence.

Holdings

1. Counsel was not ineffective for failing to move to dismiss on speedy-trial grounds because Robinson's two unlimited written speedy-trial waivers remained effective, and any such motion would have been futile absent a formal objection and demand rescinding the waivers.
2. Robinson did not establish ineffective assistance based on counsel's cross-examination decisions because the choice whether and how to cross-examine witnesses falls within the ambit of trial strategy.
3. The trial court complied with R.C. 2929.19(B)(2)(c) because it orally provided Robinson all mandatory Reagan Tokes notifications when sentencing him on the non-merged felonious-assault count.

Questions Presented

1. Whether trial counsel provided ineffective assistance by failing to file a motion to dismiss based on alleged violations of Robinson's constitutional and statutory speedy-trial rights.
2. Whether trial counsel provided ineffective assistance through the manner in which counsel cross-examined the State's witnesses.
3. Whether the trial court failed to provide the mandatory Reagan Tokes notifications when sentencing Robinson on the felonious-assault count.

Disposition

affirmed