Behl v. Georgia
Annotate this CaseEdward Behl was convicted by jury for felony murder and a weapons charge stemming from the 2017 death of Joseph Billings, a fellow resident of a homeless encampment. Behl argued for a new trial on the grounds that: (1) the trial court plainly erred in not charging the jury on voluntary manslaughter; and (2) Behl was unable to view digital discovery while incarcerated and while exercising the right to self-representation. After review, the Georgia Supreme Court concluded the trial court did not plainly err in failing to charge the jury on voluntary manslaughter, and that Behl did not preserve the issue of access to discovery. Accordingly, judgment and conviction were affirmed.
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