☢ test - Í

based on immunity as an educator under OCGA § 20-2-1001. Evidence authorized finding that defendant’s actions were “concerning, relating to, or resulting from the discipline of any student” and “that the educator acted in good faith.” Teacher here confined uncooperative students in a restrictive chair, sometimes in another room or bathroom; recorded or imitated a child’s disruptive screams so the child could hear how the child was disrupting class; and propped one child against a wall with Pickens’s own body “to prevent him from ‘plopping’ onto the floor or to get him up after he did so. The trial court concluded that this evidence was sufficient to show by a preponderance of the evidence that Pickens' actions were undertaken to maintain discipline and restore order in her classroom. Based on our review of the evidence presented, we cannot conclude that the trial court erred in its findings of fact that Pickens acted to maintain discipline and order in her classroom.” The evidence also authorized a finding that the defendant’s actions were taken in a good faith effort to help the children and were not malicious, although some of her techniques were self-developed and not approved or orthodox. “We agree with the State, however, that violations of school policy are relevant to whether an educator acted in good faith, if not determinative. But here, although the State elicited testimony that there were no county policies permitting the use of restraint and isolation of developmentally disabled students during this time period, the evidence also established that there were also no county- or state-wide policies prohibiting the practice then, as there are now. The county offered little training in methods of handling children with more difficult behavior problems, and only later made available training in the prevention and management of aggressive behavior in developmentally disabled students.” Citing Cohen (June 13, 2011), below. Hipp v. State, 293 Ga. 415, 746 S.E.2d 95 (July 11, 2013). Reversing 314 Ga.App. 520, 724 S.E.2d 825 (2012). Trial court had power after trial to reconsider its pretrial ruling that defendant wasn’t immune from prosecution, where “[b]oth the motion for new trial and pretrial order denying immunity were filed during the same term of court.” “The State urges, and the Court of Appeals concluded, that the trial court erred by reconsidering Hipp's claim of immunity in a motion for new trial because OCGA § 16–3–24.2 no longer applied once the jury rejected Hipp's self-defense claim. See Hipp, 314 Ga.App. at 522, 724 S.E.2d 825. We reject this analysis because it ignores the inherent authority of a trial court over its own orders while the case remains pending before it. To hold that the trial court has no authority to review its prior decision after the jury returns a verdict may perpetuate legal rulings that are unsound or erroneous. In the interests of promoting justice and judicial economy, a trial court should have the ability to reconsider its earlier ruling on immunity based on a different analysis of the issue or subsequent changes in the law. To the extent it holds that OCGA § 16–3–24.2 does not apply once a jury rejects the defendant's justification defense, we overrule the Court of Appeals' decision in Eason v. State, 261 Ga.App. 221(2), 582 S.E.2d 194 (2003).” Accord, Sifuentes v. State , 293 Ga. 441, 746 S.E.2d 127 (July 11, 2013). Adcock v. State, 317 Ga.App. 468, 731 S.E.2d 365 (August 23, 2012). Convictions for attempted murder and related offenses affirmed; no reversal where trial court failed to conduct pretrial evidentiary hearing on defendant’s justification claim. “Pretermitting whether the failure to conduct such a hearing could ever constitute reversible error, we have no trouble in concluding that it did not constitute reversible error here. Because Adcock chose to represent himself, the trial court conducted multiple hearings before trial. Several of these hearings involved Adcock's claim that the state had failed to provide discovery. In response to Adcock's concerns, the trial court directed the state to submit all discovery to the court as well as to Adcock. The trial court reviewed the discovery in the course of resolving Adcock's claims and therefore was familiar with the facts of the case. The court engaged in colloquy with Adcock because of his self- representation and became familiar with his contentions regarding justification. Therefore, when the court denied Adcock's motions for immunity before trial, it was familiar with the factual basis of the claims. Additionally, although Adcock requested a pretrial ruling on his immunity claim, he never requested an evidentiary hearing. And, in any event, given the absence of evidence to support the justification defenses, Adcock's claim of immunity is baseless, and any error in failing to conduct an evidentiary hearing did not harm him.” State v. Green, 289 Ga. 802, 716 S.E.2d 194 (October 3, 2011). In defendant’s murder prosecution, evidence supported trial court’s finding that defendant was immune from prosecution based on justification. Evidence showed that Waldon attacked defendant while defendant was holding a butcher knife. When Waldon attacked, “the butcher knife in Green's hand entered Waldon's right thigh and punctured the femoral artery. The trial court found that Green never attempted to stab or injure Waldon with the knife.” Based on trial court’s finding that defendant didn’t use force against Waldon, State contends that trial court’s ruling amounts to a finding of accident, not self-defense, and that immunity isn’t available for accident under OCGA § 16-3-24.2. Supreme Court, however, finds the trial court’s findings of fact sufficient to raise self- defense. “Contrary to the State's contention, OCGA § 16–3–21 does not require that a person use actual force to support a claim for justification. Pursuant to OCGA § 16–3–21(a), ‘[a] person is justified in threatening or using force against another when and to the extent that [he] reasonably believes that such threat or force is necessary to defend