Georgia v. Copeland et al.Annotate this Case
Former sheriff's deputies Henry Lee Copeland, Rhett Scott, and Michael Howell were indicted by grand jury for the felony murder (and other offenses) of Eurie Lee Martin. Each defendant sought immunity from prosecution under OCGA 16-3-24.2, claiming that his actions resulting in Martin’s death were in defense of himself or others. Following a hearing, the trial court issued an order granting immunity to Deputies Copeland, Scott, and Howell, and the State appealed. The Georgia Supreme Court determined that, in granting immunity, the trial court made findings of material fact that were inconsistent with its legal conclusions regarding the deputies’ encounter with Martin, conflated principles regarding the reasonable use of force by law enforcement with self-defense and immunity, made unclear findings of material fact with respect to whether any or all of the deputies used force intended or likely to cause death, and did not address the facts pertinent to each of the three deputies individually. For these reasons, the Supreme Court vacated the trial court’s ruling and remanded the cases for further consideration.