Orr v. State, 312 Ga. 317

Orr was indicted for malice murder, felony murder (predicated on aggravated assault/battery), multiple assault counts, and possession of a firearm during the commission of a felony; jury convicted him of felony murder, aggravated assault with a deadly weapon, aggravated battery, and the firearm count; sentenced to life plus five years.
Victim Lamario Majors was living with co-worker Ricky McGinnis; Orr was living in his car parked at the residence and accused Majors of stealing personal property (disputed whether it was a gun or cash).
On July 25, 2018, after confronting Majors and failing to find the alleged property, Orr left and returned about 15 minutes later with a gun, entered Majors’s bedroom, and shot him three times while Majors was on a video call; Majors did not have a weapon and did not move until after the first shot.
Orr gave a police statement claiming he shot in self-defense because Majors made fast movements and said, “you ain’t going to shoot me,” when Orr brandished the gun.
Orr moved for a new trial and appealed, arguing (1) insufficiency of the evidence because the State failed to disprove his claim of self-defense and (2) the trial court erred by refusing to charge voluntary manslaughter; the Supreme Court of Georgia affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence (self‑defense)	Orr: State did not disprove self‑defense beyond a reasonable doubt; he believed Majors reached for a weapon.	State: witnesses saw Orr intentionally return with a gun and shoot an unarmed Majors; jury could reject self‑defense.	Affirmed — viewing evidence in prosecution's favor, a rational juror could reject self‑defense and find guilt (Jackson standard).
Failure to charge voluntary manslaughter	Orr: ongoing insults, argument over alleged theft, frustration and provocation support a voluntary manslaughter instruction.	State: evidence was only words and a money dispute — not sudden, violent, irresistible passion; no slight evidence to authorize the charge.	Affirmed — no slight evidence of sudden, violent, irresistible passion from serious provocation; words/money dispute insufficient.

Jackson v. Virginia, 443 U.S. 307 (establishes constitutional sufficiency standard for criminal convictions)
Hayes v. State, 292 Ga. 506 (deference to jury on credibility/weight of evidence)
Morris v. State, 301 Ga. 702 (justification/self‑defense is for the jury to resolve; jury may reject such evidence)
Collins v. State, 308 Ga. 515 (slight evidence suffices to authorize a requested jury instruction)
McClure v. State, 306 Ga. 856 (whether evidence authorizes a charge is a question of law)
Johnson v. State, 297 Ga. 839 (provocation evaluated by objective reasonable‑person standard)
Hudson v. State, 308 Ga. 443 (words alone do not justify reducing murder to manslaughter)
Smith v. State, 296 Ga. 731 (fear someone might pull a gun or fighting do not demand a voluntary manslaughter charge)