Marcus C. Adkins
 
Marcus C. Adkins was convicted by jury of two counts of murder in the first degree and was sentenced to two 
consecutive terms of life imprisonment. The Evidence according to the State of Missouri and the star witness Norma 
Simmons showed that Marcus C. Adkins and Norma Simmons were married in October 1988 and separated in 
January 1990. On January 28, 1990 Ms. Simmons claimed that Marcus broke into her home armed with a rifle, 
where she lived with her two children, threatened to kill her and get to the kids. Ms. Simmons later called the police.  
The next day she obtained an ex parte temporary restraining order barring Marcus from her home.  
 
In the early morning of February 9, 1990 Ms. Simmons again claimed Marcus broke into her home where he awakened 
her and Darrell Morris.  Also in the apartment were her two children Terry and Norman and Nephew, Travis Gordon. 
Mr. Morris left the apartment and later returned with the police. Ms. Simmons also left the apartment Marcus remained 
in the apartment with Terry, Norman and Travis and didn't allow Ms. Simmons to return. Marcus Allowed Travis to leave 
the apartment, but Terry and Norman remained behind. Travis told police that the two boys were still alive and were 
watching T.V.  
 
A police sniper heard the first of two gunshots at 7:05 a.m., at 8:30 a.m. a second gunshot was heard at which time 
police entered the apartment where they found Marcus with a gunshot wound. Terry's body was found in the bathroom 
and Norman's body was found lying on the bed where both had been shot at point-blank range. That is the evidence 
according to the state. 
 
The Facts of this case are clear, clearer than the States, which Ms. Simmons contends in the evidence, to show that 
Marcus is actually innocent of this crime. Marcus did not break into the home of Ms. Simmons with a weapon in 
January 1990 and threaten to kill her and her two children as she instructed the court in order to obtain an ex parte 
temporary restraining order. This is proven by the information given by Ms. Simmons. It is her testimony that Marcus 
was driving a Pontiac 6000, Light Grey, 4 Door with Illinois Vanity Plates MCA-NJA 1. This same information 
was dispatched to the police to look for Marcus in the St. Louis area of Ms. Simmons' home. The reason the police 
did not find Marcus is because he had first been invited to Ms. Simmons home and then took her to work as she 
requested. The car that was used was a Black Two Door Plymouth owned by one of Marcus' sisters. The Pontiac 
6000 had been taken to Clifton Moore of Moore's Auto Repair Shop and he made the mechanical assessment that 
the car's transmission had gone out along with other repairs needed long before Marcus kept the invited invitation to 
Ms. Simmons apartment. 
 
Based on Mr. Moore's statement and readily available to testify during trial fell on the deaf ears of trial counsel as she 
new of his availability and willingness to be heard during the trial. Mr. Moore's testimony would have corroborated 
Marcus' statement and revealed the impeached, perjured and false information given by Ms. Simmons. 
 
Since Marcus' incarceration he has obtained a sworn affidavit from Mr. Moore with the aforementioned information 
never heard by the jury to show the false information given by Ms. Simmons to the court in order to obtain an ex parte 
order. 
 
Additional information given by Ms. Simmons in the ex parte order, was that Marcus has kidnapped her child, when in 
fact she knew all along that Marcus was suppose to pick up Norman from school and take him to receive a hair cut as 
he had requested and approved by Ms. Simmons. Her kidnapped statement resulted in the police searching for Marcus 
and Norman only to be found at his mother's residence. 
 
Furthermore, Isaac Billups Sr. has also come forward and said that Marcus could not have kidnapped Norman as he 
and the child were at his place of establishment for the purpose of getting himself and Norman a haircut, that Norman 
was not in the state of being or giving the appearance of being helpless. Mr. Billups Sr. was also willing to testify to 
these facts and to say that Marcus had been bringing Terry and Norman there for haircuts for the past three to four 
years and maintained a loving, caring and respectful relationship with Terry and Norman. That at all times Mr. Billups 
Sr. desired to testify during the trial but felt helpless to do so as trial counsel failed to call him in as a witness to further 
dispute Ms. Simmons claim of threatening to kill her and get to the kids, the same information given to obtain the ex 
parte order of protection that was before the jury without being challenged by Marcus witnesses in the Presence of 
the jury. Mr. Billups has given Marcus a sworn affidavit to these facts. 
 
Those bad acts mentioned and relied on by the State as evidence of other crimes was used as a motive, common 
scheme or plan to carry out a crime, even though they were false. On February 9, 1990 Marcus did in fact arrive at 
Ms. Simmons home invited, as she had placed numerous calls to Marcus' mom and other relatives that is was urgent 
that he comes by to see her for reconciliation purposes. At first Marcus declined the offer but later decided that it 
would be ok.  When he arrived at the residence of Ms. Simmons and did not break in as she contended, becomes 
crucial to Marcus' defense that he did not arrive at Ms. Simmons home with intentions of doing anything other than 
talking as another witness for Marcus said that she, Ms. Dorothy Staples, who lived directly across the street seen 
Marcus knocking on Ms. Simmons door and had known Marcus really well and was speaking with him until she 
identified Ms. Simmons as the person who answered the door to let Marcus inside and also testified that during 
the conversation with Marcus she did not see him with a weapon, but her testimony stands alone without the other 
witnesses of Moore and Billups Sr. 
 
After entering the apartment Marcus was pushed down from behind by an assailant running out of the apartment. 
Seconds later the police arrived and Ms. Simmons answered the door. She then later returned a second time to the 
apartment to retrieve some items in which Marcus asked her what was going on? After not giving an answer she left 
a second time to see what the police wanted. Sometime later the police called to Marcus and requested that he send 
Terry, Norman and Travis out of the apartment. Marcus complied with the police instructions and sent Travis, the 
nephew, down the stairs but could not send Norman as he was already deceased. Looking around Marcus did not 
see Terry as he later found out from trial counsel months later that Terry was in the bathroom deceased. Upon being 
asked by the police, during questioning and in their statements, did Marcus have a weapon, Ms. Simmons and Travis 
said no respectively. Immediately after leaving the apartment, Travis had given a short tape, later a sworn deposition 
that Marcus did not have a weapon and that Norman was sleeping when Marcus asked him to leave, contrary to the 
state's evidence and theory. 
 
It was during trial that Travis changed his story dramatically and said that he did see a weapon and that Norman was 
awake eating and not watching T.V., as Travis had given many inconsistent statements numerous of times.
 
When questioned by the police as to why Marcus did not send Terry and Norman out of the apartment, Marcus 
requested a phone, in which he wanted to talk with his mom and the police granted the request. It was during this 
telephone conversation that Marcus was attempting to explain to his mom that Norman was already deceased when 
he found him but didn't get the chance to do so as he was shot. The state contends during trial that this was a hostage 
situation and that Marcus had shot himself.  This was refuted by the police on the scene as they testified that it was 
impossible for Marcus to have shot himself as he was talking with the phone in one hand while holding his head in 
the other hand. There was never any gunpowder residue on the hands and clothes of Marcus to prove that he had 
actually pulled the trigger that caused the demise of Terry and Norman, nor did the state have any proof that the 
weapon in question belonged to him as they did not know who it belonged to other than establishing that it was in 
fact the murder weapon. 
 
On February 9, 1990, the day this entire ordeal took place a hand written letter had arrived at Marcus mom's house 
through regular postage mailed and written by Ms. Simmons. In this letter she admits calling Marcus' family looking 
for him. She also admits thanking him for taking care of the kids and keeping them on his medical insurance, how her 
checks are being garnished and will be put out of her apartment, couldn't get her car out of the shop for lack of money, 
that Marcus was better off than she was, requested that Marcus send her some money as she was desperate and 
needed money very bad, and wished that she was dead. 
 
During the trial the state had made numerous statements concerning Darrell Morse through Ms. Simmons on the morning 
of the crime to say that it was Marcus who had committed this act. Her testimony amounts to hear say and denied 
Marcus the right to confront his accusers.  Trial counsel was questioned by Marcus parents and stressed that she 
subpoena Mr. Morse to the stand to either confirm or deny Marcus was the one who had ran him out of the house 
according to Ms. Simmons and the state, but failed to do so. An affidavit secured by trial counsel after trial concerning 
her lack of duty to secure Mr. Morse for trial has said that she would be the one calling the witness and therefore must 
vouch for his credibility and could not cross examine him. She also felt that Mr. Morse or any other person could not 
identify someone in the dark under circumstances existing at that time. 
 
There was no independent identification of Marcus by Mr. Morse prior to the time of trial and yet allowed the state to 
use his name in an effort to show guilt against Marcus. Marcus family, after conviction, had hired an investigator who 
sought to do, with great success, what trial counsel and the state failed to do, i.e., to run a check on Mr. Morse and 
find out why he made it virtually impossible to make himself available as a defense or state witness. Mr. Morse had 
given a false name and a false social security number and address. 
 
As can be seen from this the need to be unavailable as a witness and the desire not to be dealt with under the justice 
system during a murder trial, creates a viable reason for not being made available for questioning.  Furthermore he 
happens to be an eyewitness of the perpetrator. This information could have exonerated while making a clear cogent 
showing that would have proven Marcus' actual innocence. 
 
Counsel failed to investigate and secure the requested witnesses' evidence that was critical in that it would have 
corroborated the impeachment of Ms. Simmons and significantly challenge the states theory as to the motive behind 
the decedents murder while showing jurors unschooled in the laws of intricacies may interpret a failure to a defense by 
counsel as proof of Marcus guilt.  
 
St. Louis City Medical Examiner, Phillip M. Burch, had testified during trial as to the cause of death of both Terry 
and Norman. This cause he gave was a gunshot wound to the head as the State of Missouri was very concerned 
as the number of shots allegedly fired and presumably heard by the police, which attempts to give credence to the 
police but falls short according to his report. In Dr. Burch's report for Terry he says that the brain stem and the 
cerebral hemisphere further disclose the wound track through the left cerebral hemisphere, track from back to front, 
right to left slightly and upward via scalp, occipital bone, left cerebral hemisphere.  For Norman his report says the 
brain stem and cerebellum are unremarkable on gross examination. Coronal sections of the cerebral hemisphere 
further disclose the gunshot wound through both cerebral hemispheres, track from left to right, front to back and 
upward via scalp, left temporal bone, brain, occipital bone. I'm not a pathologist and neither do I pretend to make 
it so, however, there seems to be more damage to Norman than there is to Terry with each sustaining a single gunshot 
wound. When Dr. Burch says in his report that the wound track for Terry is through the left cerebral indicating that 
there is also a right, but for Norman the gunshot wound through both cerebral hemispheres not just left or either right 
can give an indication of the damage being caused or more than one gunshot wound injuring Norman. If this is so, it 
becomes understandable that the state did not know of the number of shots fired, as they did not hear any or what 
they thought they heard did not add up to reason or rationale, thus abandoning the shot count theory. 
 
Marcus remains confined for a crime that the testimony of witnesses and competent counsel could have prevented. 
After his conviction the above mentioned affidavits and reports from a private investigator on a third witness that 
shows information of a false address and social security number which creates a viable reason not to be dealt with 
under the Justice System.
 
Furthermore, he happens to be an eyewitness of the perpetrator. This information could have exonerated while making 
a clear cogent showing that would have proven Marcus' actual innocence.
 
For additional information, questions, requests, or to just wish him the best, contact Marcus directly at the address 
below, thank you. 
 
Marcus C. Adkins
#179416-5B11 
Potosi Correctional Center 
Rt. 2, Box 2222 
Mineral Point, MO 63660-9600

 

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