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afterwards, the defendant asked if he could still get money from the robbery, he met with others in the group to discuss the crime, and he then drove them around in search of an insider involved in the crime).” Higuera-Guiterrez v. State, 298 Ga. 41, 779 S.E.2d 288 (November 2, 2015). Evidence didn’t support defendant’s convictions for murder and conspiracy to traffic cocaine. “In the present case, the State has failed to elicit any evidence showing that Guiterrez was participating in the criminal scheme either before or during the actual commission of the crimes. The only evidence that the State has presented for this critical time period is the fact that Guiterrez lived in the Magnolia Apartments, where testimony indicated that the drugs were originally delivered. There was no testimony, however, that the drugs were taken to Guiterrez’s apartment, and, as a result, the best that can be inferred is that the drugs were taken somewhere within the complex. As for the time period in which the drug transaction and the shootings occurred, the State presented no evidence that Guiterrez was present. … Although the State and the trial court relied on Guiterrez’s actions and knowledge after the commission of the crimes to support his convictions, this evidence is insufficient to satisfy the standard of OCGA § 16–2–20. At best, it would show that Guiterrez was an accessory after the fact, not a party to the crimes.[fn] ‘At common law and under modern practice, an accessory after the fact is not considered an accomplice to the underlying crime itself, but is guilty of a separate, substantive offense in the nature of obstruction of justice.’ Purvis v. State, 208 Ga.App. 653, 654, 433 S.E.2d 58 (1993). The State, however, did not charge Guiterrez with being an accessory after the fact.” Platt v. State, 335 Ga.App. 49, 778 S.E.2d 416 (October 27, 2015). Evidence supported convictions for voluntary manslaughter and related offenses where two groups, one associated with Platt, had a gunfight. Each group suffered one fatality. Held, Platt could be convicted of voluntary manslaughter of both his own co-conspirator and the member of the other group. “Where there is evidence that the parties mutually agreed to engage in a gunfight to settle a dispute, a rational jury can find that all of the ‘participants in the gun battle shared a common criminal intent—to assault each other with guns.’ Emmanuel v. State, 300 Ga.App. 378, 380(1), 685 S.E.2d 361 (2009), quoting Taylor v. State, 296 Ga.App. 212, 213(1)(a), 674 S.E.2d 81 (2009). See also Coe v. State, 293 Ga. 233, 235(1), 748 S.E.2d 824 (2013); Coker v. State, 209 Ga.App. 142, 143, 433 S.E.2d 637 (1993). Given this shared criminal intent, a defendant who was a party to the gun battle can be held criminally liable for a shooting injury or death caused by the battle, even if the shot was fired by an opponent of the defendant. See id. See also State v. Spates, 779 N.W.2d 770, 780–781 (Iowa 2010) (‘The primary distinction between garden-variety aiding and abetting and mutual-combat aiding and abetting is that the existence of mutual combat provides a factual basis for holding a defendant combatant vicariously liable for the murderous conduct of any other combatant, even an opponent of the defendant.’). … Platt thus could be held criminally liable for his friend Clark’s death, even if the shot was fired by a rival gang member, so long as the death was proximately caused by the gunfight.” Cash v. State, 297 Ga. 859, 778 S.E.2d 785 (October 19, 2015). Felony murder convictions affirmed. Trial court properly declined to charge jury on involuntary manslaughter, based on Cash’s claim that he didn’t know his co-conspirator, Wright, had a shotgun. “A defendant who lacks knowledge that his co-defendant possessed the gun that was used to commit an aggravated assault may nevertheless be a party to the aggravated assault. See Cornette v. State, 295 Ga.App. 877, 881–883(3), 673 S.E.2d 531 (2009). To the extent that the evidence shows (as the jury obviously concluded it did) that the appellant and Wright shared a criminal intent to commit an assault upon Jackson, the appellant is chargeable with the foreseeable acts undertaken by Wright in the furtherance of that shared intent, even if Wright did something or employed some instrument that the appellant subjectively did not expect. And even assuming that the appellant did not know that Wright was armed with a shotgun, it certainly is foreseeable that an assault in the circumstances presented here—an early-morning ambush on the side of a road to which the victims were lured unwittingly—might involve the use of a deadly weapon and may result in serious injury or loss of life. Accordingly, when Wright employed a deadly weapon to assault, the appellant was chargeable with that use of a deadly weapon, so long as he and Wright shared a common intent to assault. On these facts, the appellant either was a party to murder and aggravated assault, or he was guilty of no crime at all. See Igidi v. State, 251 Ga.App. 581, 586(4), 554 S.E.2d 773 (2001); Hopkins v. State, 227 Ga.App. 567, 568(1), 489 S.E.2d 368 (1997), overruled on other grounds, Mullins v. State, 270 Ga. 450, 451(2), 511 S.E.2d 165 (1999).” Butts v. State, 297 Ga. 766, 778 S.E.2d 205 (October 5, 2015). Felony murder and related convictions affirmed; evidence supported convictions for armed robbery and murder despite defendant’s claim that he didn’t know his accomplice was armed. “[A] coconspirator to a robbery may be convicted of armed robbery even if he did not have actual prior knowledge that his fellow conspirator intended to use a gun, where the use of an offensive weapon was naturally or necessarily done in furtherance of the robbery, see Hicks v. State, 295 Ga. 268, 272–273 (759 S.E.2d 509) (2014); the

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