Behl v. State

315 Ga. 814

FINAL COPY S23A0377. BEHL v. THE STATE. PETERSON, Presiding Justice. Edward Behl appeals convictions for felony murder and a weapons charge stemming from the death of Joseph Billings, a fellow resident of a homeless encampment.1 Behl argues 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. We conclude that the trial 1 The crimes took place on January 10, 2017. A Chatham County grand jury…