Garner v. State, 303 Ga. 788

On March 14, 2015, Stevie Lamar Garner shot Patrick Wall, who later died from a chest gunshot wound after crashing his car fleeing the scene.
Weeks earlier the victim had assaulted Garner with a pistol and taken Garner’s shotgun; the victim later texted Garner apologizing and offered to meet alone wearing no shirt and with hands up to make amends.
Garner had told others in March he was "out for blood," planned to kill the victim, and tried to recruit people to "set [the victim] up."
When the victim arrived at Garner’s trailer and apologized from his car, Garner pulled a gun and shot him; Garner was seen placing a lockbox (containing a gun matching the murder weapon) under an outbuilding.
A jury convicted Garner of murder, felony murder, aggravated assault, aggravated battery, and related firearm offenses; he was sentenced to life without parole plus five years.
On appeal, Garner argued the trial court erred by refusing to instruct the jury on self-defense.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred in refusing to give a self-defense jury instruction	Garner: slight evidence supported self-defense because the victim previously assaulted and robbed him and did not comply with the shirt/hands condition, so Garner reasonably feared imminent harm to himself and his girlfriend	State: no evidence the victim posed an imminent threat at the meeting; Garner was the aggressor who planned violence and shot the victim while he was apologizing	Court held no error: there was not even slight evidence to justify a self-defense charge; Garner was the aggressor

Jackson v. Virginia, 443 U.S. 307 (establishes standard for sufficiency of the evidence review)
Green v. State, 302 Ga. 816 (slight evidence suffices to authorize a requested jury instruction)
Brunson v. State, 293 Ga. 226 (self-defense instruction not required where evidence cannot support it)
Hicks v. State, 287 Ga. 260 (affirming refusal to give self-defense instruction when evidence does not support it)
Broussard v. State, 276 Ga. 216 (defendant must present evidence of fear to support self-defense claim)