Williams v. the State, 333 Ga. App. 879

Williams was arrested for possession of cocaine after an investigator saw him pick up a pill bottle near a grocery store and tell the officer "it's drugs" and that they belonged to another person.
The officer recovered the pill bottle and an officer performed a field test that was positive for cocaine; a GBI chemist later performed two tests also positive for cocaine.
The prosecutor initially failed to tender the physical cocaine into evidence before the State rested.
Williams moved for a directed verdict after the State rested, arguing the State had not met its burden because the drug sample had not been produced.
The trial court denied the directed verdict, allowed the State to reopen to tender the cocaine over Williams’s objection, and admitted the exhibit; a jury convicted Williams and the trial court sentenced him to 15 years.
Williams’s motion for new trial was denied; he appealed arguing the trial court erred in denying his directed verdict motion based on the State’s initial failure to produce the physical drug.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by denying directed verdict because the State failed to tender the physical drug before resting	State: testimony and chemical test results sufficiently proved identity and possession; State may reopen to admit exhibit	Williams: absence of the physical drug at the time of the directed verdict meant the State did not meet its burden to prove corpus delicti	Court: No error — testimony and GBI tests provided reasonable assurance of identity; physical production is not always required; reopening to admit exhibit was permissible

Jackson v. State, 252 Ga. App. 268 (Test for reviewing sufficiency of evidence on appeal)
Slade v. State, 222 Ga. App. 407 (Directed verdict standard and relevance of nonproduction of drugs)
Chancey v. State, 256 Ga. 415 (Corpus delicti in drug-possession cases: physical production not invariably required)