State v. Brown

Summary

The court held that the appellate record was insufficient to determine whether the trial court ruled on Brown’s immunity claim for the armed-robbery count or whether it denied immunity on that count. Because the omission could reflect either a failure to rule or a decision that did not conflict with immunity on the other counts, the court vacated and remanded for express findings and further analysis. The court otherwise rejected the State’s challenges to the trial court’s factual findings supporting Brown’s self-defense immunity.