Dix v. State, 307 Ga. App. 684

Dix was convicted by a jury of cocaine possession, marijuana possession (<1 ounce), obstruction of a law enforcement officer, and driving on a suspended license.
The offense evidence centers on a January 4–5, 2009 incident at a rural traffic safety checkpoint where Dix fled into thick woods with his child after being detained.
A small bag of cocaine and a small bag of marijuana were found along Dix's attempted escape route, with the marijuana bag wet but the evidence described as not tied to Dix personally.
The marijuana bag lay about 20 feet along the route; the cocaine bag was found near the second fall, described as wet with a saliva-like coating.
Prior similar incidents included: (i) 2008 marijuana possession at a checkpoint; (ii) 2003 cocaine possession with attempts to swallow; (iii) 1999 cocaine found during jail booking.
Dix challenged sufficiency of the drug evidence and moved for mistrial after the prosecutor referred to marijuana as a misdemeanor during closing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence supports drug convictions	Dix	Dix	Sufficient evidence supported convictions
Whether prosecutor's remarks required mistrial	Dix	Dix	No reversible error; curative instructions adequate

Jackson v. Virginia, 443 U.S. 307 (U.S. Supreme Court 1979) (sufficiency standard: rational finder could convict beyond reasonable doubt)
Sirmans v. State, 301 Ga. App. 756 (Ga. App. 2009) (circumstantial evidence can support conviction)
Banks v. State, 281 Ga. 678 (Ga. 2007) (trial court authority on mistrial and curative measures)
Ballard v. State, 281 Ga. 232 (Ga. 2006) (curative instruction suffices to cure prejudice)
Johns v. State, 274 Ga. 23 (Ga. 2001) (authority on improper prosecutorial remarks and mistrial denial)