Georgia Supreme Court Affirms Denial of Plea-Withdrawal Motion; Vacates Vehicular-Homicide Sentence

The Supreme Court of Georgia on Aug. 12, 2025, affirmed the trial court's denial of Yohansea Yusef Robinson's motion to withdraw his guilty plea while vacating the sentence imposed on the vehicular-homicide count.

Robinson appealed the denial after he told new counsel he had experienced a seizure roughly an hour before the plea colloquy and later said at the withdrawal hearing that he did not recall the proceeding and "had not known that he was pleading guilty." The Court concluded the trial court did not err in crediting plea counsel's testimony that Robinson was coherent during the colloquy and understood the rights he waived.

The opinion, authored by Chief Justice Peterson, summarizes the factual background leading to the plea. According to the State's factual presentation at the plea hearing, Robinson drove erratically, led police on a high-speed chase at speeds exceeding 100 miles per hour, lost control, and crashed into a utility pole; his passenger, Felicia Putney, was ejected and died. The State charged Robinson with multiple counts, including felony murder (Count 1), fleeing and attempting to elude, first-degree vehicular homicide (Count 5), and several traffic-related offenses. Before trial, the State filed a notice of intent to seek a recidivist sentence of life without parole.

On the day Robinson's trial was to begin, plea negotiations resulted in the State withdrawing the recidivist notice, moving to nolle prosequi Counts 2—4 and 7—11, and agreeing to recommend a life sentence on Count 1 and concurrent sentences on Counts 5 and 6 if Robinson pleaded guilty to those counts. At the plea colloquy, Robinson confirmed under oath that he understood the court and stated he took "Keppra for petit mal seizures." The trial court accepted the plea and sentenced Robinson to life with the possibility of parole on Count 1, a 15-year concurrent term on Count 5, and a 10-year concurrent term on Count 6.

Represented by new counsel, Robinson moved post-sentencing to withdraw his plea on the ground that a seizure rendered his plea involuntary. At the withdrawal hearing, plea counsel testified that while reviewing paperwork with Robinson before the plea, he "kind of froze" with his head down and arms limp for about two minutes; counsel said Robinson indicated that the episode was consistent with the seizures he experienced. Plea counsel said she reoriented Robinson by asking questions for about an hour and that, based on her observations and prior mental-health–court experience, she believed he was capable of understanding and intentionally entering the plea. Counsel testified she would not have completed the plea paperwork or submitted the plea if she had thought Robinson did not understand the rights discussed.

Robinson testified that he did not remember having a seizure that day and that he learned about the episode from another inmate who had witnessed it. He said he did not recall details of the plea proceeding and maintained he had not known he was pleading guilty.

The trial court denied the motion to withdraw the plea, crediting plea counsel's account and finding Robinson's testimony at the withdrawal hearing not credible and inconsistent with his on-the-record answers during the plea colloquy. On appeal, the Supreme Court reviewed the trial court's factual findings for clear error and its credibility determinations for deference. Citing Powell v. State and related precedent, the Court reiterated that post-sentencing withdrawal of a guilty plea is discretionary and permitted only to correct a manifest injustice, such as a plea entered involuntarily or without understanding the nature of the charges.

The Court rejected Robinson's argument that the trial court erred by accepting the plea about an hour after the claimed seizure. The opinion noted that although the trial court expressed some skepticism about whether a seizure actually occurred, it did not rely on that skepticism in denying relief. Instead, the Court emphasized the record showing Robinson answered questions appropriately during the plea colloquy, confirmed he understood the charges and consequences, and stated no one coerced him into pleading guilty. The Court also rejected Robinson's suggestion that the better practice or a legal requirement would have been to obtain a medical examination before proceeding; it found no authority mandating such a step and held that the absence of a medical consultation did not, by itself, undermine the court's conclusion that Robinson knowingly and voluntarily pled guilty where plea counsel testified she would not have proceeded had she thought otherwise.

Although Robinson did not raise it, the Supreme Court identified and corrected a sentencing error. The Court concluded Count 5 (vehicular homicide) merged with Count 1 (felony murder) because both charged the death of the same victim. Citing Diamond v. State and related authorities, the Court vacated the sentence imposed on Count 5 as a matter of law. Because the remainder of Robinson's sentence was proper, the Court did not remand for resentencing and affirmed in part and vacated in part.

The judgment was affirmed in part and vacated in part. All Justices concurred except Justice Land, who did not participate.