Christopher Calmer shot two sheriff’s deputies who responded to a 911 call at his home; one deputy died and the other survived. A jury convicted Calmer of malice murder and related offenses. He argued that the trial court should have instructed the jury on justification and voluntary and involuntary manslaughter and that he was entitled to immunity from prosecution under Georgia’s justification-immunity statute. The Georgia Supreme Court affirmed. The court held that the evidence did not support the requested lesser-offense instructions because Calmer’s account was inconsistent with the officers’ unlawful-entry theory required for justification. The court also held that the evidence at the immunity hearing authorized the finding that Calmer was not acting in response to an unlawful and forcible entry or an unlawful arrest. The court rejected the remaining claims and left the convictions and life-without-parole sentence in place.