Holiman v. State, 313 Ga. App. 76

Jamison Holiman was convicted of trafficking in 400+ grams of a cocaine-containing mixture after a bench trial in Fulton County.
The conviction rested on evidence of joint constructive possession with his brother Royrecaus in a shared apartment.
Police found substantial cocaine quantities in the apartment: about 95 grams in the kitchen and about 373 grams in the second bedroom, plus 123 grams of cocaine base and related drug paraphernalia.
The apartment contained other indicia of distribution (scales, baking soda, packaging), cash, and a strong odor of marijuana; Jamison had been inside the apartment for hours prior to police entry.
Jamison referred to the apartment as “our house” and attempted to warn his brother when police approached; he was alone in the apartment for a significant period before his brother arrived.
The State introduced evidence of two prior similar transactions to support intent to possess and distribute cocaine.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Applicability of Reid principle where co-possessors are prosecuted separately	Jamison argues sole possession must be shown because Royrecaus was not prosecuted in Georgia.	State may rely on joint possession evidence even if co-possessor is prosecuted elsewhere or not prosecuted.	State permitted to prove joint constructive possession; Reid principle not binding here.
Sufficiency of construct ive possession proof for 400+ grams	Evidence shows only presence; cannot prove Jamison had constructive possession.	Totality of circumstances supports intent and power to control; strong inferential evidence.	Sufficient circumstantial evidence supports constructive possession, including intent and control over the contraband.
Proof of 10%+ cocaine purity	Purity not proven for the entire mixture; sampling issues exist.	Lab reports establish purity above 10%; samples were representative.	Lab reports were sufficient to prove 10%+ purity; samples represented the whole quantity.

Reid v. State, 212 Ga. App. 787 (1994) (addressed sole vs. joint possession when co-possessors are prosecuted)
Davenport v. State, 308 Ga. App. 140 (2011) (circumstantial possession requires more than presence; equal access does not mandate acquittal)
Bailey v. State, 294 Ga. App. 437 (2008) (ownership/control of premises gives presumptive possession of contraband found there)
Stroud v. State, 286 Ga. App. 124 (2007) (lab proof of cocaine purity admissible in trafficking cases)
Lombardo v. State, 187 Ga. App. 440 (1988) (lab reports sufficient to establish purity of cocaine-containing mixtures)