Supreme Court of Georgia

Marrow v. State

August 26, 2025

Summary

The court affirmed Marrow’s convictions and sentences, holding that the trial court did not plainly err by declining to instruct the jury on voluntary manslaughter and that Marrow failed to establish ineffective assistance of trial or post-trial counsel. The court concluded that the evidence showed, at most, fear or interpersonal tension rather than serious provocation, and that the alleged counsel errors either were not deficient, caused no prejudice, or were cumulative only in a minor way. All Justices concurred.