Jackson v. State, 301 Ga. 878

Willie Jackson lived with sister Willie Mae; on May 3–4, 2006 he became convinced she had taken his Social Security check.
On the evening of May 4, Jackson threatened his sister, created a disturbance to lure her out, retrieved a knife, and entered her bedroom.
Jackson stabbed Willie Mae repeatedly; the blade broke in her body; he then used a machete. She died from 31 stab wounds.
After a 911 call, police and S.W.A.T. found Jackson at the scene (with duct tape on his head and the apartment barricaded); he was arrested.
Jackson was convicted by a jury of malice murder and possession of a knife during a felony; he was sentenced to life plus probation. He appealed arguing the trial court should have instructed the jury on voluntary manslaughter and on insanity.

Issue	Jackson's Argument	State's Argument	Held
Whether the trial court erred by refusing a voluntary-manslaughter instruction as a lesser included offense	Jackson argued the evidence supported passion or provocation sufficient for voluntary manslaughter	The State argued the provocation was insufficient: the belief about the missing check developed over time, threats were made an hour earlier, and actions were deliberate	Court: No error — evidence did not show sudden, irresistible passion; voluntary manslaughter instruction not warranted
Whether the trial court erred by refusing an insanity instruction	Jackson asserted he suffered from schizophrenia/mania and acted strangely, supporting an insanity defense	The State argued Jackson presented no evidence he lacked capacity to distinguish right from wrong or acted under delusional compulsion	Court: No error — Jackson failed to meet burden to prove legal insanity; no evidence he could not distinguish right and wrong

Jackson v. Virginia, 443 U.S. 307 (standard for sufficiency of evidence)
Dugger v. State, 297 Ga. 120 (distinguishing provocation for manslaughter from self-defense)
Gresham v. State, 289 Ga. 103 (argument over money not serious provocation)
Merritt v. State, 292 Ga. 327 (words alone ordinarily not serious provocation)
Alvelo v. State, 290 Ga. 609 (defendant bears burden to prove insanity by preponderance)
Phillips v. State, 255 Ga. 539 (medical descriptors of odd behavior insufficient for legal insanity)
Lawrence v. State, 265 Ga. 310 (medical diagnosis of mental illness alone does not establish legal insanity)