Kevon Watkins, convicted of felony murder after choking his sister to death, argued that the trial court in his bench trial should have found him guilty of voluntary manslaughter instead. The Supreme Court of Georgia affirmed. It held that the evidence did not require the factfinder to accept a sudden-passion theory and supported the felony-murder judgment the trial court chose to enter. The case underscores the deference given to a trial judge's resolution of competing homicide theories in a bench trial.