Strozier v. State
313 Ga. App. 804
Ga. Ct. App.2012Background
- Strozier, an inmate at Dooly State Prison, was involved in a trash-area incident on Feb 16, 2004.
- A fellow inmate, Pinkins, found a white bag with apparent drugs in the Lobby Trash Can and alerted authorities.
- Strozier was seen with the bag later, and officers discovered marijuana-containing bags in the I.D. Trash Can after Strozier was searched and detained.
- The State argued Strozier had control/knowledge of the drugs; Strozier asserted he was merely performing his trash disposal duties.
- The trial court denied Strozier’s new-trial motion; the Court of Appeals reversed, finding insufficient evidence of Strozier’s knowledge or intent to possess the drugs.
- There were multiple potential actors with access to the trash area, and no direct link between Strozier and the drugs was proven.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of circumstantial evidence to prove possession with knowledge | Strozier argues evidence fails to exclude alternatives. | State asserts circumstances show Strozier had control/intent. | Conviction reversed; insufficient proof of knowledge/intent. |
| Error in proving linkage between Strozier and drugs beyond proximity | Strozier denied knowledge; no link to Johnson or drugs. | State failed to connect Strozier to the drugs or Johnson. | Conviction reversed for lack of requisite connection/intent. |
Key Cases Cited
- Rogers v. State, 290 Ga.App. 18 (Ga. App. 2011) (reversal when only proximity links defendant to contraband)
- Millsaps v. State, 300 Ga.App. 383 (Ga. App. 2009) (insufficiency where no knowledge of contraband shown)
- Collinsworth v. State, 276 Ga.App. 58 (Ga. App. 2005) (affirming conviction for possession where inmate's cell contained marijuana)
- Webb v. State, 249 Ga.App. 214 (Ga. App. 2001) (same rationale for possession with knowledge/intent)