Edward Behl and Joseph Billings lived at a homeless encampment. After Billings learned Behl had touched him sexually while he was passed out, they fought, separated, and later argued again; Behl lured Billings to his tent and stabbed him. A jury acquitted Behl of malice murder but convicted him of felony murder and a knife offense. He challenged the omitted voluntary-manslaughter instruction and his access to digital discovery while jailed and self-represented. The Supreme Court affirmed. Because Behl objected only to omission of an involuntary-manslaughter charge, it reviewed the voluntary-manslaughter claim for plain error. The earlier fight, intervening time, and later argument did not show serious provocation or that Behl acted from passion rather than fear or self-defense; no clear error required the instruction. The discovery claim was waived: the materials had been disclosed to prior counsel, Behl knew of them, and he never sought access by motion or continuance or objected to evidence he could not review. The Court did not reach the claim’s merits. A footnote expressed concern about categorical jail restrictions; Justice McMillian, joined by Justice LaGrua, concurred separately, noting that inmates could request courtroom access and the record did not show a categorical denial.