Riggs v. State, 306 Ga. 759

Glenn Vincent Riggs II lured Dr. Charles Mann III to his home via Craigslist, claiming sex, but intended to rob him; Riggs restrained, strangled, and bludgeoned Mann, then wrapped the body, dumped it, and abandoned Mann's car.
Police found blood in the car, an index card with Riggs' contact info, and Mann's belongings and blood at Riggs' home; Riggs sent a message confessing and later gave a recorded statement directing police to the body.
Riggs was indicted for malice murder, felony murder (aggravated assault predicate), and armed robbery; convicted by a jury (Oct. 2016) and sentenced to life without parole plus a consecutive 20 years; felony murder vacated by operation of law.
At trial Riggs testified that he lured Mann to rob him and claimed he feared being raped and for his life; on cross he admitted he never told police about fearing rape.
On redirect the trial court barred Riggs from testifying that he had been raped at age 11; Riggs argued on appeal that exclusion was error and, alternatively, that counsel was ineffective for not preserving the issue.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Exclusion of testimony about childhood rape	Riggs: testimony was relevant to his subjective fear, rehabilitate credibility after cross, and could support voluntary manslaughter	State: testimony about remote childhood molestation was irrelevant, prejudicial, not probative of voluntary manslaughter or self-defense/insanity; Allison inapplicable	Court: exclusion not an abuse of discretion; testimony irrelevant to voluntary manslaughter, justification/self-defense, or insanity; any error harmless
Relevance to voluntary manslaughter	Riggs: fear of rape stemming from childhood abuse could show provocation/sudden passion	State: provocation is judged by reasonable-person standard; remote childhood event not probative of provocation here	Court: provocation judged by reasonable person; prior childhood rape irrelevant to provocation for voluntary manslaughter here
Ineffective-assistance claim for failing to preserve error	Riggs: if exclusion wasn't preserved, remand for ineffectiveness hearing requested	State: issue either preserved at trial or, if not, defendant failed to brief/argue ineffectiveness	Held: claim inadequately briefed and deemed abandoned; objection at trial was preserved, so ineffectiveness claim fails
Sufficiency review	N/A (Riggs did not challenge sufficiency)	State: evidence overwhelmingly supports convictions	Court: under Jackson v. Virginia standard, evidence was sufficient to support convictions

Jackson v. Virginia, 443 U.S. 307 (constitutional sufficiency standard)
Culpepper v. State, 289 Ga. 736 (operation-of-law vacatur of felony-murder conviction)
Davis v. State, 301 Ga. 397 (admission/exclusion of evidence reviewed for abuse of discretion)
Prothro v. State, 302 Ga. 769 (provocation standard for voluntary manslaughter)
Lewandowski v. State, 267 Ga. 831 (reasonable-person barometer for provocation)
Bailey v. State, 301 Ga. 476 (reaffirming reasonable-person standard)
Collins v. State, 306 Ga. 464 (prior sexual abuse years earlier not relevant to voluntary manslaughter)
Virger v. State, 305 Ga. 281 (limits on using remote mental-state evidence absent an insanity defense)
Allison v. State, 296 Ga. App. 379 (old Evidence Code decision; not controlling here)
Felix v. State, 271 Ga. 534 (issues unsupported by argument are deemed abandoned)