Johnson v. State, 297 Ga. 839

On May 28, 2008 Farren Johnson shot and killed his stepfather; he later told police he did it because the victim was “taking [his mother] away” and that he had “snapped.”
Johnson purchased the .38 nine days earlier; he returned to the living room, shot the unarmed victim four times in the back of the head, then called 911 and admitted the killing.
Evidence showed a history of antagonism and prior physical confrontations between Johnson and the victim, disputes over money, and removal of the family’s furniture earlier that day.
Five mental-health experts testified: three for defense diagnosed or opined about a delusional disorder/delusional compulsion; two State/ court-appointed experts found insufficient evidence of such a disorder and concluded anger and frustration motivated the killing.
Johnson was tried, found guilty but mentally ill of malice murder and related counts, and challenged only the trial court’s refusal to charge voluntary manslaughter.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by refusing a voluntary manslaughter jury charge	Johnson: evidence of anger, frustration, family disputes, and the victim’s laughter provided at least slight evidence of provocation	State: provocation was not "serious" as a matter of law; evidence showed planning and coolness, not sudden passion	No error; charge refusal upheld — objective standard not met

Jackson v. Virginia, 443 U.S. 307 (establishes standard for sufficiency of evidence review)
Blake v. State, 292 Ga. 516 (trial court must give lesser-included manslaughter charge only if any slight evidence supports it)
Humphrey v. Lewis, 291 Ga. 202 (defines voluntary manslaughter provocation standard)
Hall v. Lewis, 286 Ga. 767 (provocation judged by objective reasonable-person standard)
Partridge v. State, 256 Ga. 602 (defendant’s subjective fragility cannot alter objective provocation standard)
Pace v. State, 258 Ga. 225 (similar facts held insufficient as a matter of law for voluntary manslaughter)
Morgan v. State, 290 Ga. 788 (psychological evidence of subjective rage does not by itself show legally sufficient provocation)
Johnson v. State, 292 Ga. 785 (prior decision applying objective-provocation analysis to similar facts)