Supreme Court of Georgia

Watkins v. State

April 19, 2022313 Ga. 573

Summary

The Supreme Court of Georgia affirmed Watkins's felony murder conviction, holding that the trial court did not err in refusing to reduce the offense to voluntary manslaughter because the alleged provocation was not sufficient to excite a sudden, violent, and irresistible passion in a reasonable person. The Court emphasized that the voluntary manslaughter statute imposes an objective standard and that the trial court’s discretionary judgment was proper.