Cf. Jackson v. State, 294 Ga. 431, 433 (2), 754 S.E.2d 322 (2014) (holding that the trial court properly granted a motion to join charges for trial where the murder of one victim and the armed robbery of another victim were committed within a mile, within a short period of time, and with the same gun). See also Doleman v. State, 304 Ga. 740, 744-745 (3), 822 S.E.2d 223 (2018) ("[S]everance was not mandatory because all of the offenses involving [the appellant], including the ones which did not occur on the day of the murder, reflected a continuous crime spree."); Davis v. State, 279 Ga. 11, 13 (3), 608 S.E.2d 628 (2005) (holding that severance of counts based on crimes occurring "on separate days" was not mandatory because "the State explained [at the pretrial hearing] that it expected the evidence to show that the crimes were part of a continuing crime spree"). [14] Appellant also has not shown that "severance [was] necessary to achieve a fair determination of [his] guilt or innocence as to each offense."
In the related area of severance, severance is not mandatory where crimes were committed as part of a continuing spree. Davis v. State, 279 Ga. 11, 13(3), 608 S.E.2d 628 (2005). In this case, the murder of Phillips was committed less than a mile from the armed robbery of Scott, and both occurred within a short period of time from one another.
Id. at 386(2)(c), 589 S.E.2d 69; see OCGA § 16–11–106(b)(1).See Marlowe, 277 Ga. at 386(2)(c), 589 S.E.2d 69; OCGA § 16–2–20(a) ("Every person concerned in the commission of a crime is a party thereto and may be charged with and convicted of commission of the crime."); see also Davis v. State, 279 Ga. 11, 13(4), 608 S.E.2d 628 (2005) ; Walker v. State, 305 Ga.App. 607, 613(1)(c), 699 S.E.2d 902 (2010). Compare Stovall v. State, 287 Ga. 415, 420–21(5), 696 S.E.2d 633 (2010) (holding that appellant's separate convictions on possession of a firearm during the commission of a crime merged when the continuous crime involved only a single victim).
Even if we were to treat the Bibb Finance and Macon Finance robberies as one crime spree, there were four individual victims in this case — the two Bibb Finance employees and the two Macon Finance employees. Consequently, Walker's four separate convictions on the firearm possession charges were proper. See Davis v. State, 279 Ga. 11, 13 (4) ( 608 SE2d 628) (2005). 2.
Moreover, Short admitted to police that the initial attack, including the kidnapping, hijacking, and armed robbery, occurred at the Douglas County apartment complex. Under these circumstances, it is highly improbable that any alleged error contributed to the verdict, rendering it harmless. See Davis v. State, 279 Ga. 11, 12-13 (2) ( 608 SE2d 628) (2005); Howard v. State, 220 Ga. App. 579, 583 (2) ( 469 SE2d 746) (1996). 6. Short argues that the trial court erred in refusing to charge the jury that "the elements of proof that one is a party to a crime, or an accomplice, require proof of common criminal intent."
Here, the crime spree consisted of an eight-week period during which the co-defendants committed a series of robberies and assaults using the same weapons and stolen vehicles from previous offenses. See Davis v. State, 279 Ga. 11, 608 S.E.2d 628 (2005) (severance was not mandatory where charges arose from two shooting sprees in which several people were injured and two victims were killed and where the State expected evidence to show that the crimes were part of a continuing crime spree connected to defendant’s drug-dealing). Further, because Doleman failed to prove he was prejudiced by the refusal to sever any of the related offenses, he cannot show that the trial court abused its discretion in denying the motion.
The trial court denied the appellants' motion solely on the ground that "there is a rational relationship between the County's sign restrictions and its interests in aesthetics and traffic safety."Coffey v. Fayette County, 279 Ga. 11 ( 610 SE2d 41) (2005). We determined that the rational relationship test cited by the trial court was an incorrect standard, holding:
[Copyrighted Material Omitted] [279 Ga. 11] Maria Murcier-Ashley, Marietta, for Appellant.Jeffrey H. Brickman, Dist. Atty., Robert M. Coker, Asst. Dist. Atty., Hon. Thurbert E. Baker, Atty. Gen., Raina Jeager Nadler, Asst. Atty. Gen., for Appellee.