Supreme Court of Georgia

Behl v. State

March 7, 2023315 Ga. 814

Summary

The court affirmed Behl’s convictions for felony murder and a weapons offense. It held that the trial court did not plainly err by omitting a voluntary-manslaughter instruction because the evidence did not clearly show passion-based provocation rather than fear or self-defense. The court also held that Behl waived his due-process claim concerning access to digital discovery by failing to raise the issue before or during trial or seek relief from the trial court.