"The appropriate response to a witness’ show of emotion is a matter addressed to the trial court’s discretion." Williams v. State , 276 Ga. 384, 385 (2), 578 S.E.2d 858 (2003) (citing Todd v. State , 274 Ga. 98, 102 (5), 549 S.E.2d 116 (2001) ). We have previously noted the grim reality that emotional outbursts are "reasonably expected by one who is a close friend of a murder victim."
Relying on these principles, this Court has rejected the argument that a co-conspirator to a robbery must know that his fellow conspirator has a gun before he can be found guilty of felony murder based on armed robbery. See Williams v. State, 276 Ga. 384, 386, 578 S.E.2d 858 (2003) (holding that the defendant's knowledge of whether his coconspirator had a gun “was not a necessary component of his guilt for armed robbery and, consequently, for felony murder” and that “[a]ll that the State was required to prove was that Appellant was a member of a conspiracy to rob the store and that [his co-conspirator's] use of the weapon was naturally or necessarily done in furtherance of that crime”). The United States Supreme Court recently held that, under the federal aiding and abetting statute, see 18 USC § 2, a person may be convicted of aiding and abetting the federal crime of using or carrying a firearm in connection with a drug trafficking crime, see 18 USC § 924(c), only if he had advance knowledge that a co-defendant would use or carry a firearm.
Stinson, supra, 294 Ga. App. at 185 (1). Additionally, Johnson could be convicted of hijacking a motor vehicle even if he had no knowledge that Anderson was planning to use a gun to perpetrate the crime because Anderson's use of the gun was "naturally or necessarily done in furtherance of the conspiracy [to steal a vehicle] even though not part of the original agreement. (Cit.)" Williams v. State, 276 Ga. 384, 386 (4) ( 578 SE2d 858) (2003) (in armed robbery case, the State was only required to prove that defendant was a member of a conspiracy to rob the store and that co-conspirator's use of a weapon was naturally or necessarily done in furtherance of that crime). The jury could also find that Johnson was a party to the crime because he drove Anderson to the Spring Road neighborhood to steal a "random" car, and had prior knowledge that Anderson intended to steal a car.
When a group of individuals join together to plan and commit a crime, each member of the criminal plan is responsible for the criminal acts of the others – regardless of whether a particular act was part of the original plan – as long as such crimes were "naturally or necessarily done" in the execution or furtherance of the common purpose. Williams v. State , 276 Ga. 384, 386 (4), 578 S.E.2d 858 (2003) ; see also Menzies v. State , 304 Ga. 156, 160 (II), 816 S.E.2d 638 (2018). And "all the participants in a plan to rob are criminally responsible for the act of each committed in the execution of the plan and which may be said to be a probable consequence of the unlawful design," Williams v. State , 304 Ga. 658, 662, 821 S.E.2d 351 (2018) (citation and punctuation omitted), a principle we have specifically held applies to murders committed during the commission of "a crime that foreseeably [leads] to murder" – such as armed robbery – perpetrated by a group that shares a common criminal intent.
(Citations and punctuation omitted.) Williams v. State , 276 Ga. 384, 385 (2), 578 S.E.2d 858 (2003) ; see also Ragan , 299 Ga. at 834 (3), 792 S.E.2d 342 ("Trial courts are vested with great discretion to grant or deny mistrials because they are in the best possible position to determine whether one is warranted[.]"). However, we do not reach the merits of this enumeration because a "motion for mistrial must be promptly made as soon as the party is aware of the matter giving rise to the motion."
Butts v. State , 297 Ga. 766, 770 (2), 778 S.E.2d 205 (2015) (citation omitted). See also OCGA § 16-2-20 (defining parties to a crime); Williams v. State , 276 Ga. 384, 385 (3), 578 S.E.2d 858 (2003) ("A party to a felony may be convicted for any murder that occurs as a result of the commission of that felony, without regard as to whether he commits, intended to commit, or acted to commit the murder of the victim.") (citation and punctuation omitted). Any rational trier of fact could have found Satterfield guilty beyond a reasonable doubt of the crimes for which he was convicted.
As a result, "[t]he intent of the actual killer may be imputed to the other active members of the conspiracy even though the homicide may not have been a part of the original common design." Williams v. State, 276 Ga. 384, 385 (3), 578 S.E.2d 858 (2003). Thus, the jury could find Kemp criminally responsible for Gray’s death because his participation in the robbery carried with it the foreseeable risk that Hogans would bring a gun to the robbery and use it to shoot and kill Gray.
(Citations omitted.) Williams v. State, 276 Ga. 384 , 385 (2) (578 SE2d 858 ) (2003).
(Citations and punctuation omitted.) Williams v. State, 276 Ga. 384, 385(2), 578 S.E.2d 858 (2003). 3. Foster argues that the trial court erred by admitting into evidence the incriminating letter written by Foster to Johnson because it was not properly authenticated.
]" Moore v. State, 278 Ga. 397, 401 (2) (e) ( 603 SE2d 228) (2004). See also Williams v. State, 276 Ga. 384, 387 (5) ( 578 SE2d 858) (2003). 4. Appellant further contends that the prosecution withheld exculpatory evidence consisting of a statement given by Ms. Henry to Detective Carl Price, to the effect that the knife which was used in both incidents did not come from her apartment.