Marrow v. State, S25A0720

Keith Lamont Marrow was convicted of three counts of malice murder and firearm offenses for the deaths of Courtney German, William Mullins III, and Shayla Curtis in Savannah, Georgia in April 2017.
At trial, Marrow admitted to shooting the victims but claimed he acted in self-defense based on a perceived threat and his belief that other gang members were plotting against him.
Strong forensic evidence corroborated his involvement, including matching fingerprints at the crime scene, ballistics evidence, and his own admissions during police interviews.
The trial court sentenced Marrow to three concurrent life sentences without parole and additional consecutive sentences for firearm offenses; other charges were merged or vacated.
Marrow's motion for new trial was denied, and he appealed, raising multiple issues including the failure to instruct the jury on voluntary manslaughter and claims of ineffective assistance of both trial and post-conviction counsel.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Failure to instruct on voluntary manslaughter	Evidence warranted a lesser-included offense charge	No evidence of serious provocation, only self-defense supported	No error, no instruction required
Ineffective assistance—prior felony stipulation	Jury learned prejudicial details about prior robbery	Evidence was not emphasized; conviction supported by other evidence	No prejudice, claim fails
Ineffective assistance—not calling witnesses	Uncalled witnesses would have supported self-defense theory	Testimony was cumulative, not unreasonable decision	No deficiency, claim fails
Ineffective assistance—not objecting to hearsay	Counsel failed to preserve objection to prejudicial drug-use evidence	Statement cumulative of other admitted evidence	No prejudice, claim fails
Cumulative error by counsel	Combined effect of errors requires new trial	Errors minor, did not affect outcome	No cumulative prejudice
Ineffective assistance—post-conviction counsel	New counsel failed to present needed evidence for IAC claims	No showing of prejudice or alternative outcome	No prejudice, claim fails

Miranda v. Arizona, 384 US 436 (police must inform suspects of rights before custodial interrogation)
Strickland v. Washington, 466 US 668 (two-prong test for ineffective assistance of counsel)
Smith v. State, 296 Ga. 731 (standard for voluntary manslaughter charge; requires serious provocation)
Jackson v. State, 317 Ga. 95 (no prejudice if evidence of guilt is overwhelming and prior act evidence is not emphasized)
Powell v. State, 307 Ga. 96 (no deficiency if evidence did not support instruction requested)
Butler v. State, 313 Ga. 675 (decisions on witness testimony generally strategic and not deficient unless unreasonable)
Jennings v. State, 318 Ga. 579 (hearsay admitted harmlessly if cumulative to other evidence)