Valdez v. State, 310 Ga. App. 274

In December 2007, MANS conducted an undercover cocaine purchase operation.
Valdez drove the vehicle while Ortiz-Hernandez sat in the back; Castaneda stood outside using a cell phone.
Castaneda handed a bag containing cocaine to the informant; the informant gave Castaneda cash from MANS funds.
The officer-secretive takedown occurred after Castaneda delivered the bag and Valdez took the funds.
Lab testing showed the bag contained cocaine, about 28.27 grams, 36.1% purity.
Valdez was convicted of trafficking in cocaine; his claims include insufficient evidence and juror-bias in voir dire.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence	Valdez argues no possession or joint possession evidence.	State contends joint constructive possession and participation shown.	Evidence supports joint constructive possession; verdict sustained.
Juror bias and voir dire	Valdez argues a juror with bias should have been excused.	Trial court acted within discretion; responses showed impartiality.	No reversible error; trial court did not abuse discretion.

Martinez v. State, 303 Ga.App. 71 (Ga.App. 2010) (constructive possession doctrine and aiding/abetting admissible evidence)
Navarro v. State, 293 Ga.App. 329 (Ga.App. 2008) (joint possession suffices for trafficking conviction)
Wright v. State, 302 Ga.App. 332 (Ga.App. 2010) (circumstantial-evidence hypotheses governed by reasonable-fitness standard)
Croom v. State, 217 Ga.App. 596 (Ga.App. 1995) (juror-challenge for cause and demeanor impact on voir dire)
Spence v. State, 238 Ga. 399 (Ga. 1977) (relationship to a witness not per se disqualifying; fixed opinions required for disqualification)
Jones v. State, 184 Ga.App. 4 (Ga.App. 1987) (voir dire bias must be shown to be fixed and unchangeable)
Taylor v. State, 243 Ga. 222 (Ga. 1979) (trial court's voir dire discretion affirmed)
Bryant v. State, 270 Ga. 266 (Ga. 1998) (necessity of transcript for voir dire issues on appeal)