Martin v. State, 308 Ga. 479

On May 6–7, 2013, James Wood and Russell Jacobs were robbed and murdered during a robbery; Maxwell shot Jacobs and later shot Wood after a struggle.
Marquez Deshawn Martin drove and accompanied co-defendants Jordan Maxwell, Dave-Von Sapp, and Sameria Carter; Martin participated in prior robberies that night, was armed, and later took/possessed stolen property.
Martin was convicted by a jury of four counts of felony murder (among other counts) and sentenced to concurrent life sentences without parole on all four murder counts; other gang-act sentences also imposed.
At trial Martin’s defense was lack of knowledge of the robberies; he presented three witnesses to testify to his good character.
The trial court charged the jury with the pattern instruction on defendant’s good character but declined to include additional “note” language (referencing State v. Hobbs) requested by defense counsel; Martin claims counsel was ineffective for failing to object to that omission.
The Supreme Court of Georgia affirmed the convictions (rejecting the ineffective-assistance claim) but vacated part of the sentencing because there were only two victims and remanded for resentencing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel was ineffective for not objecting to omission of the Hobbs‑referencing note from the good‑character jury charge	Martin: counsel should have objected because the omitted language was necessary to inform the jury that good character can itself create reasonable doubt	State: the pattern instruction given adequately instructed the jury; objection would have been meritless, so failure to object not deficient	Court: No ineffective assistance — pattern charge was adequate (citing Williams and related authority); claim fails
Whether sentencing on four felony‑murder counts was erroneous given two victims	Martin: sentences on four murder counts are improper because only two murders occurred	State: (did not establish authority to sustain four separate murder sentences)	Court: Sentences vacated in part; two murder verdicts vacated by operation of law and case remanded for the trial court to resentence and determine which verdicts remain (per Cowart)

Strickland v. Washington, 466 U.S. 668 (ineffective assistance two‑prong standard)
Jackson v. Virginia, 443 U.S. 307 (sufficiency of the evidence standard)
Romer v. State, 293 Ga. 339 (standard for deficient performance review)
Wesley v. State, 286 Ga. 355 (ineffective assistance framework application)
Marshall v. State, 297 Ga. 445 (presumption counsel's performance adequate)
Williams v. State, 304 Ga. 455 (pattern good‑character charge deemed adequate)
State v. Hobbs, 288 Ga. 551 (discussed historical treatment of character charge)
Jackson v. State, 305 Ga. 614 (reaffirming adequacy of current pattern charge)
Parker v. State, 305 Ga. 136 (pattern charge adequately communicates that character evidence may generate reasonable doubt)
Coe v. State, 274 Ga. 265 (error of sentencing on more murder counts than victims)
McCoy v. State, 303 Ga. 141 (vacatur of verdicts by operation of law)
Cowart v. State, 294 Ga. 333 (trial court discretion on which verdicts are deemed vacated on remand)