Watkins v. State

872 S.E.2d 293, 313 Ga. 573
CourtSupreme Court of Georgia
DecidedApril 19, 2022
DocketS22A0016
StatusPublished
Cited by7 cases

This text of 872 S.E.2d 293 (Watkins v. State) is published on Counsel Stack Legal Research, covering Supreme Court of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Watkins v. State, 872 S.E.2d 293, 313 Ga. 573 (Ga. 2022).

Opinion

313 Ga. 573 FINAL COPY

S22A0016. WATKINS v. THE STATE.

MCMILLIAN, Justice.

Following a bench trial in August 2019, Kevon Watkins was

convicted of felony murder in connection with the death of his sister,

Alexus Watkins.1 On appeal, Watkins asserts that the trial court

erred in declining to find him guilty of the offense of voluntary

manslaughter instead of felony murder. We disagree and affirm.

1. Viewed in the light most favorable to the verdict, the

evidence presented at trial showed that Watkins lived in Bibb

County with his mother, Latoya Watkins, his 13-year-old brother,

1 The crimes occurred on February 2, 2018. On May 1, 2018, a Bibb

County grand jury indicted Watkins for felony murder predicated on aggravated assault (Count 1) and aggravated assault (Count 2). At a bench trial held on August 1 and 2, 2019, Watkins was found guilty of both counts. On August 6, 2019, the trial court sentenced Watkins to serve life in prison for Count 1; Count 2 was merged into Count 1 for sentencing purposes. Watkins timely filed a motion for new trial. Following a hearing on October 30, 2019, the trial court denied the motion for new trial on December 2, 2019. Watkins timely appealed. The case was originally docketed in the Court of Appeals but was subsequently transferred to this Court, where it was docketed to the term of court beginning in December 2021 and submitted for a decision on the briefs. K. W., his infant nephew, C. T., and his 19-year-old sister, Alexus.

On February 2, 2018, at 5:17 p.m., Latoya called 911 to ask for

assistance with Watkins, who was 16 years old at the time, because

he was “disobedient” and “being disorderly.” A few minutes later, K.

W. called 911 and reported that Watkins had Alexus in a “choke

hold,” that she was “knocked out,” and that Watkins “was

threatening to beat” their mother. He also told the dispatcher that

their mother was trying to get Watkins off of Alexus, but Watkins

was “still on [his] sister.”

When Deputy Isaac Munguia arrived at the Watkinses’ home

at 5:30 p.m., he was met by Latoya at the front door. She told him

that Watkins and Alexus were still fighting and pointed to the back

bedroom. Deputy Munguia entered the home but did not hear any

fighting or arguing. When he found Watkins and Alexus in the

corner of the back bedroom, Watkins appeared to be holding Alexus

down. Deputy Munguia told Watkins twice to let go of his sister, and

when Watkins finally did so, her body “just kind of flopped.” Alexus

was nonresponsive, with her tongue hanging out of her mouth, and

2 it appeared that she had urinated on herself. Deputy Munguia

checked for a pulse, requested additional assistance, and

immediately began administering CPR. He continued CPR until

additional help arrived, but he was unable to get a response from

Alexus. A video and audio recording of the incident recorded by

Deputy Munguia’s body camera was played at trial.

Alexus was transported to a hospital, where she was

resuscitated and admitted into the intensive care unit with a

diagnosis of cardiorespiratory failure with anoxic brain injury.

Alexus experienced another cardiac arrest and suffered irreversible

brain damage and multi-organ failure. She died the next day. The

medical examiner determined that Alexus’s cause of death was

anoxic brain injury, caused by a lack of oxygen to the brain due to

asphyxiation. The medical examiner observed multiple abrasions on

Alexus’s neck, sustained from a “friction-type injury,” and an

abrasion to her sternocleidomastoid muscle as a result of pressure

applied to her neck. The extent of Alexus’s injuries indicated a

prolonged period of asphyxia or oxygen deprivation, most likely for

3 at least 15 minutes. The medical examiner explained that when

pressure is applied to a person’s neck in a way that cuts off the blood

supply, that person will eventually become unconscious and go

“limp” or “motionless,” obviously indicating that something is wrong.

The medical examiner further opined that if Alexus had been

released within a minute or two of being held, she would have

survived.

In her statement to law enforcement officers, Latoya explained

that Watkins, who had a “nasty attitude” that day, had been playing

video games and had reset the password for the Internet so that no

one else could use the Internet. In response, Latoya unplugged the

Internet router and put the video game box in her bedroom. Watkins

then went into her room, trying to fight her, and Alexus stepped in

to protect her mother. Alexus grabbed Watkins in a bear hug and

told him to “chill out” and to stop trying to fight with their mother.

Watkins and Alexus began “tussling” on the floor, and Watkins put

Alexus in a chokehold. Although Latoya and K. W. tried hitting and

punching Watkins while yelling for him to let Alexus go, they could

4 not break the grip that Watkins had on Alexus.2

After being advised of his Miranda3 rights, Watkins agreed to

speak with Investigator Marcus Baker. Watkins said that he and his

mother had gotten into an argument about the Internet and that his

sister had jumped in between them to stop the argument. Watkins

then pushed his mother away and told her, “I don’t want to hit you.”

Alexus grabbed Watkins, and they began fighting. Watkins put

Alexus in a chokehold and continued to hold her even after she

stopped moving because he “was mad.” While he was holding Alexus,

his mother called his father, and his little brother tried to get him to

let go of Alexus, but he did not let her go until the second time

Deputy Munguia asked him to step outside.

Watkins testified on his own behalf at trial and, contrary to his

custodial statement, claimed that Alexus rushed into the room and

hit him. He explained that he then held Alexus to protect himself

2 At trial, however, Latoya testified that Alexus came into her bedroom,

charged at Watkins, and hit Watkins first. 3 See Miranda v. Arizona, 384 U.S. 436 (86 SCt 1602, 16 LE2d 694)

(1966). 5 because he was concerned that she would get back up and start

fighting again. On cross-examination, he admitted that it was

possible Alexus was fighting against him because she was trying to

find a way to breathe. Watkins claimed he did not notice when

Alexus stopped moving.

In closing argument, defense counsel asserted that the

evidence showed that the strangulation was accidental and that, if

anything, the trial court should convict Watkins of voluntary

manslaughter instead of felony murder. The trial court expressly

considered and rejected this argument. And, in denying Watkins’s

motion for new trial, the court again concluded that voluntary

manslaughter was not supported by the evidence because Alexus’s

actions were not such a serious provocation as would be sufficient to

excite a sudden, violent, and irresistible passion in a reasonable

person.

2. On appeal, Watkins asserts that the trial court erred in

failing to find him guilty of the offense of voluntary manslaughter

6 instead of felony murder.4 See Edge v. State, 261 Ga. 865, 865 (2)

(414 SE2d 463) (1992) (“[W]here the jury renders a verdict for

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872 S.E.2d 293, 313 Ga. 573, Counsel Stack Legal Research, https://law.counselstack.com/opinion/watkins-v-state-ga-2022.