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limited to that necessary to suddenly snatch property from a victim who had no time to react before the taking was completed. Robert E. Clearly, Jr., Kurtz Criminal Offenses and Defenses in Ga., Robbery (Sec. (II)(E)) (2006 ed.). In the present case, the evidence did not show robbery by sudden snatching. But even if the evidence could be construed to show that Franklin applied no other force than that necessary to quickly grab the man’s wallet from his pocket, this method of robbery requires proof that the man was aware of the taking before it was completed. King v. State, 214 Ga.App. 311-312 (447 S.E.2d 645) (1994). The evidence shows that, because the man was extremely intoxicated, he was unaware of the taking until he was informed of what had happened after it was completed. Likewise, there was no evidence of constructive force supplied by intimidation, threat or other means, so there was no proof of this method of robbery. As to robbery by the use of actual force, we find that the record was devoid of evidence that Franklin used any actual force sufficient to prove this method of robbery. … Under these circumstances, the actual force used by Franklin to pat the man’s pockets and to reach in his pocket and take the wallet was not actual force sufficient to show robbery by the method set forth in OCGA § 16-8-40(a)(1). [footnote: These circumstances are distinguished from those where a robber takes property without resistance from an unconscious or incapacitated victim who the robber has put into the helpless condition prior to the taking. In those cases, even though the victim is incapable of resisting when the property is taken, the actual force used by the robber prior to the taking to render the victim helpless is force essential to accomplish the subsequent taking and is sufficient to show the offense of robbery by use of force. Young v. State, 251 Ga. 153, 156-157 (303 S.E.2d 431) (1983). ] See Hicks v. State, 232 Ga. 393, 402-403 (207 S.E.2d 30) (1974) (no armed robbery because taking property from the victim occurred while the victim was asleep).” Lancaster v. State, 281 Ga.App. 752, 637 S.E.2d 131 (October 4, 2006). “Lancaster argues that because he was charged with robbing Daniels with a pistol, and because the evidence showed that Daniels’s assailant used a pistol, he could not be convicted of robbery by intimidation, which does not require the use of an offensive weapon. See OCGA § 16-8-40(a)(2). This argument is incorrect. OCGA § 16-8-41 ‘unequivocally provides that robbery by intimidation is a lesser included offense in the offense of armed robbery, and it necessarily follows that evidence authorizing a conviction of robbery by the use of an offensive weapon would authorize a conviction of robbery by intimidation.’ Holcomb v. State, 230 Ga. 525, 527 (198 S.E.2d 179) (1973). In light of the evidence that Lancaster robbed Daniels by use of a firearm as an offensive weapon, which would authorize a conviction of armed robbery, the robbery by intimidation jury charge and conviction were authorized.” Smith v. State, 281 Ga.App. 91, 635 S.E.2d 385 (August 14, 2006). Evidence was insufficient to support defendant’s conviction for robbery. “ The offense of robbery by sudden snatching is complete … only when the victim becomes conscious that something is being taken from him and for some reason is unable to prevent the taking. McNearney v. State, 210 Ga.App. 582, 583 (436 S.E.2d 585) (1993). This consciousness must be present before the taking is complete. Id. Here, Smith took the bag from a room adjacent to the small store in which the victim was working, and then passed within a few feet of her with the bag stuffed down his pants. The evidence showed, however, that the victim got ‘an uneasy feeling’ after she saw Smith break into a run outside the store, and that this feeling became a consciousness that she had been robbed only when a customer told her that she had seen Smith leaving the office. As in Grant v. State, 226 Ga.App. 506, 507 (486 S.E.2d 717) (1997), which also involved the theft of deposit money from a store’s back office while employees were diverted, this evidence was insufficient to establish that the victim was aware that something was being taken from her before that taking was complete. We therefore reverse Smith’s conviction for robbery by sudden snatching. Id.” Magana-Gonzalez v. State, 277 Ga.App. 195, 626 S.E.2d 167 (January 10, 2006). “A conviction for robbery by intimidation , OCGA § 16-8-40(a)(2) ... requires proof that the theft was attended with such circumstances of terror – such threatening by word or gesture, as in common experience, are likely to create an apprehension of danger, and induce a person to part with his property for the safety of his person. (Citation and punctuation omitted.) Johnson v. State, 195 Ga.App. 56, 58(1)(b) (392 S.E.2d 280) (1990).” Owens v. State, 271 Ga.App. 365 , 609 S.E.2d 670 (January 21, 2005). “[T]he theft of keys to a nearby car, which keys were stolen from the immediate presence of the victim, suffices to show the theft of the vehicle from the immediate presence of the victim. Johnson v. State , 246 Ga.App. 109, 112(3), 539 S.E.2d 605 (2000).” Holloway v. State, 269 Ga.App. 500, 604 S.E.2d 844 (September 9, 2004). “ A defendant who takes multiple items from a victim in one transaction cannot be convicted of multiple robberies , even though the prosecution arguably uses different evidence to prove each taking. [Cit.] The question is whether the thefts involve a single transaction or sequential crimes. [Cit.] When one victim is robbed of more than one item in a single transaction, only one robbery may
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