Smith v. State, 316 Ga. App. 175

Smith was convicted of trafficking in cocaine after a car stop revealed 1,417.61 grams of cocaine in the trunk and cash in the car.
The car was a rental; Hampton was listed as a driver, but Smith was not; Smith claimed she did not know cocaine was in the car.
During trial, Smith and Hampton gave conflicting accounts about the trip and ownership of the car, with defenses alleging others had access.
The jury found Smith jointly and constructively in possession of the cocaine, supporting trafficking conviction.
Smith appealed alleging insufficient evidence and ineffective assistance of counsel, challenging admission of Hampton’s prior-conviction evidence.
The trial court’s ruling on the motion for new trial was reviewed, with the appellate court affirming the conviction and addressing the ineffective-assistance claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the evidence sufficient for trafficking conviction?	Smith argues mere presence in car and lack of knowledge negate possession.	State contends facts show joint constructive possession and knowledge.	Evidence sufficient to support conviction beyond reasonable doubt.
Did trial counsel render ineffective assistance by not challenging Hampton's prior-conviction evidence?	Smith claims failure to object prejudiced outcome.	State argues counsel’s strategy was reasonable and supported by trial circumstances.	No ineffective assistance; strategy within wide professional discretion.
Did the equal-access/constructive-possession framework apply correctly to Smith’s case?	Equal-access defense suggests others had equal access to car, undermining possession.	Equal-access does not automatically exonerate; jury may infer possession from circumstances.	Evidence supported joint possession and ability to exercise dominion; insufficient to negate possession.

Hughes v. State, 297 Ga. App. 217 (2009) (directed verdict standard and sufficiency review)
Bray v. State, 294 Ga. App. 562 (2008) (jury credibility and conflicts in evidence)
Castillo v. State, 288 Ga. App. 828 (2007) (equal access defense; constructive possession standards)
Lockwood v. State, 257 Ga. 796 (1988) (definition of actual possession)
Fluker v. State, 296 Ga. App. 347 (2009) (constructive possession; reliance on surrounding circumstances)
Ferrell v. State, 312 Ga. App. 122 (2011) (possession analysis and evidentiary standards)
Cochran v. State, 300 Ga. App. 92 (2009) (possession and knowledge in drug cases)
Robinson v. State, 277 Ga. 75 (2003) (standards for ineffective-assistance review)
Moreland v. State, 263 Ga. App. 585 (2003) (trial tactics and reasonableness)
Grier v. State, 273 Ga. 363 (2001) (tactics are generally strategic; not per se ineffective)