Statev.Hylton
Before trial for felony murder and related crimes, Shawn Hylton sought immunity, claiming he shot Lathan Davenport in self-defense after Davenport beat and stomped him and later advanced again. The State argued the trial court’s order lacked adequate findings and that Hylton was not facing a threat when he fired. The Supreme Court of Georgia affirmed, holding that the trial court need not make express findings if its factual and credibility determinations can be inferred from the ruling. Viewing the evidence in the light most favorable to the ruling, the Court found sufficient support for a reasonable belief that deadly force was necessary to prevent death or great bodily injury, so immunity under OCGA § 16-3-24.2 was proper.
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