The 42-year-old was sent to prison again on Tuesday, for up to 11 years, after fatally bashing and choking to death an Airbnb guest over a $210 unpaid bill owed to another man.

Ramis Jonuzi died on the front lawn of the Brighton East home where he'd been renting a room for 10 days in October 2017. His death followed a sustained assault by three men, instigated by Colton.

The 36-year-old had rented a room from Craig Levy and Ryan Smart who are already behind bars for manslaughter over the attack.

Colton, who was living in the garage, also pleaded guilty to manslaughter, though that plea was not accepted until prosecution evidence wrapped up in his murder trial earlier in March.

He must serve at least eight years before he's eligible for parole, Supreme Court Justice Elizabeth Hollingworth ordered on Tuesday.

She called the attack cowardly, vicious and unprovoked against a restrained and defenceless man who was trying to get away.

The attack started because Colton got involved in the rental dispute "that was none of your business".

"You were by far the most physically violent and were involved for the longest time," she said, noting he could only do all he did because of Levy and Smart's involvement.

After Colton punched Mr Jonuzi until he was unconscious, Levy and Smart carried him outside and Colton dragged him around the front yard by his chin.

With his knee on his victim's back, Colton choked Mr Jonuzi, and later tried to have Levy hit the struggling man with a wrench. Levy refused and called police.

"Mr Jonuzi did not fight back, and posed no threat to any of you at any stage," Justice Hollingworth said.

Colton told police a "pack of lies" after the killing, accusing Mr Jonuzi of being the primary aggressor and downplaying the nature and extent of the violence.

Mr Jonuzi could not be revived by police or paramedics.

After finding out Mr Jonuzi had died, Justice Hollingworth said Colton still called his victim a "scumbag" who deserved everything he got.

It was revealed in a pre-sentence hearing that the assault on Mr Jonuzi was not Colton's first violent attack on a housemate.

He served three months of a five-month jail sentence in Norway in 2013 for hitting a man in the head and holding him by the throat while he slept in one of several attacks after arguments about living arrangements.

Justice Hollingworth said Colton had reasonable prospects of rehabilitation and noted he showed some signs of remorse, though fell short of full responsibility or acknowledging he had anger management issues.

Levy and Smart are serving maximum seven-and-a-half and nine-year sentences respectively.

Australian Associated Press