Martin v. State, 290 Ga. 901

On New Year's Eve 2008, Martin attended a neighbor's party and argued with Mwangi over closing a door to block cold air.
About an hour later, Kamau and Mwangi stood outside trying to de-ice a windshield; Martin then retrieved a knife and confronted Mwangi, stabbing him as Mwangi backed away.
Wachira witnessed Martin wielding a knife; Mwangi was unarmed; Martin dropped the knife and later moved his car; two knives were found in a fertilizer bag at Martin's home with no blood on them.
Mwangi died at the hospital from two stab wounds; a jury convicted Martin of felony murder, aggravated assault, and possession of a knife, with a sentence of life for felony murder and additional years for the knife conviction.
Evidence included the knives with no blood and the testimony of witnesses; the appellate court upheld the conviction after evaluating claims of ineffective assistance of counsel and evidentiary rulings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ineffective assistance based on the taped statement	Martin argues counsel erred by not redacting invocation of counsel and prayer to God.	State contends invocation and prayer portions do not render counsel ineffective and that admission was strategic.	No reversible error; invocation not inadmissible and playing the full tape was a reasonable trial strategy.
Withdrawal of self-defense testimony due to court ruling	Martin claims trial court limited his self-defense justification by truncating relevant testimony.	State contends Martin waived the issue by acquiescing and, even if preserved, there was no error.	Waived; in any event, testimony about fear and self-defense was effectively presented and no harm shown.
Impact of silent stipulations being read aloud	Martins asserts the court should have read aloud two stipulations to the jury.	Stipulations were provided in writing and properly explained to the jury.	No reversible error; written stipulations and instructions were adequate.
Miranda-era voluntariness of drink statement	Statement about drinking occurred during custodial interaction without Miranda warning.	Questioning was non-interrogative and harmless; evidence already suggested drinking.	Harmless error; no impact on defense given other testimonial context.

Jackson v. Virginia, 443 U.S. 307 (1979) (sufficiency of evidence standard)
Rowe v. State, 276 Ga. 800 (2003) (invocation of counsel not automatically improper as silence)
Benham v. State, 259 Ga. 249 (1989) (invocation-to-remain-silent must directly affect defense)
Lytle v. State, 290 Ga. 177 (2011) (trial strategy and evidentiary decisions reviewed for reasonableness)
Holcomb v. State, 268 Ga. 100 (1997) (waiver/strategy considerations in appellate review)
Strickland v. Washington, 466 U.S. 668 (1984) (standard for ineffective assistance claims)
Fuller v. State, 277 Ga. 505 (2004) (Strickland prongs in Georgia)
Robinson v. State, 277 Ga. 75 (2003) (application of legal principles to facts in reviewing trial court decisions)