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circumstances in the case sub judice (including evidence that Foster got into the van after being asked if he wanted to make some money, that he accepted two meals and a night in a hotel from Williams and that he threw the envelope containing the forged check out the van window as the traffic stop was being instigated) sufficient to authorize a rational trier of fact to determine beyond a reasonable doubt that Foster knowingly possessed the forged check with the intent to defraud. Floyd v. State, 251 Ga.App. 346, 349(1) (553 S.E.2d 658) (2001) (Conviction for second degree forgery affirmed when the evidence showed that check stuffed into passenger door of defendant's automobile was drawn on the same account as forged check cashed by defendant shortly before), compare Nelson [ v. State, 302 Ga.App. 583, 585(1) (691 S.E.2d 363) (2010)] (Evidence was insufficient to support defendant's conviction for second degree forgery when it revealed only that defendant merely possessed a counterfeit bill, but did not prove intent to defraud.)” Duvall v. State, 289 Ga. 540, 712 S.E.2d 850 (July 11, 2011). Reversing 305 Ga.App. 545, 699 S.E.2d 761 (2010), in VGCSA prosecution, trial court erred in denying defendant’s request to charge on mistake of fact based on defendant’s claim that he didn’t know what the pills he possessed were. Arrested for loitering and obstruction of officers, a search incident to arrest revealed three Ambien tablets in defendant’s pockets. “The entire basis of appellant’s defense at trial was that he knew he possessed the sleeping aids, but that he believed the pills were some form of over-the- counter medication and not Zolpidem Tartrate.” Trial court declined charge on mistake of fact, and Court of Appeals agreed, “construing OCGA §§ 16-13-30(a) and 16-13-75 not to require the defendant to know that the pills he possessed were a controlled substance.” Supreme Court disagrees: “[T]he criminal intent required by OCGA § 16-13-30(a) and 16-13-75 is intent to possess a drug with knowledge of the chemical identity of that drug. … Therefore, possessing Zolpidem Tartrate, which one knows or understands to be Zolpidem Tartrate is a violation of OCGA § 16–13–30(a) because Zolpidem Tartrate is a controlled substance. On the other hand, possessing Zolpidem Tartrate, which one believes or understands to be an over-the-counter medication (such as Doxylamine Succinate, sold as an over-the-counter sleep aid under the brand name Unisom) is not a crime because the requisite mens rea is not present. It is this latter scenario which appellant asserts to be the case. … Appellant’s knowledge of the chemical identity of the substance in his possession is purely a question of fact. As such, it should have been a question for the jury, and the jury should have been instructed to consider the defense of mistake of fact.” Court of Appeals took the facts differently, believing that the defense was that “appellant knew that the three pills in his possession were Zolpidem Tartrate, but that he asserted a defense based on not knowing that Zolpidem Tartrate is a controlled substance under Georgia law. Were that the case,” Supreme Court says, “the Court of Appeals’ analysis of the matter would have been correct.” Accord, Mohamed (February 16, 2012), above. Query: does this open the door for a drug couriers to remain willfully ignorant of what substances they possess? See Maddox v. State , 272 Ga.App. 440, 612 S.E.2d 484 (February 10, 2005) (arson case; approving charge on willful ignorance as supplying the element of knowledge of critical facts), and cases cited therein; Taylor v. State , 293 Ga.App. 551, 667 S.E.2d 405 (September 16, 2008) (forgery case; ‘ mistake of fact constitutes a defense to a criminal charge only if it is not superinduced by the fault or negligence of the [defendant]’). Serna v. State, 308 Ga.App. 518, 707 S.E.2d 904 (March 17, 2011). Convictions for possession of dangerous drug and related offenses affirmed; evidence supported conviction, though defendant claimed he didn’t know the substance he possessed was on the list of dangerous drugs. “Serna argues that because he was unaware of the precise chemical compound in the bottle and of its ‘dangerous drug’ status in the Criminal Code, he lacked the requisite criminal intent to be guilty of possessing the dangerous drug. Nevertheless, ‘[i]gnorance of the law excuses no one.’ OCGA § 1-3-6. ‘The fact that the defendant was ignorant of the fact that [ ]he was violating the law does not relieve h[im] of criminal intent if [ ]he intended to do the act which the legislature has prohibited.’ Wilson v. State, 57 Ga.App. 839, 841 (197 SE 48) (1938). See Mincey v. State, 303 Ga.App. 257, 257-258 (692 S.E.2d 809) (2010). Serna does not contend that he did not possess the chemical or that his possession was accidental. Furthermore, with respect to Serna's knowledge of the nature of the chemical, … there was evidence supporting an inference that Serna used the dangerous drug to sedate his sexual battery victim. This conduct demonstrated Serna's knowledge of the harmful effect of the compound and authorized the jury to conclude that Serna intended to possess a dangerous drug, even if he was subjectively unaware of the precise chemical compound in the bottle and its regulated nature.” Accord, Cooper (May 3, 2012), above. Mincey v. State, 303 Ga.App. 257, 692 S.E.2d 809 (March 29, 2010). Defendant’s conviction for possession of a telecommunications device by an inmate affirmed; State wasn’t required to show that defendant knew it was illegal for him to possess a cell phone. “‘Ignorance of the law excuses no one.’ OCGA § 1-3-6; see generally Hameen v. State, 246 Ga.App. 599, 600(1), 541 S.E.2d 668 (2000). A defendant's ignorance of the fact that he was violating the law does not relieve him of criminal intent if he intended to do the act that the legislature prohibited. Wilson v. State, 57 Ga.App. 839, 841, 197 S.E. 48 (1938). Criminal intention may be found from the circumstances connected with the act for which the

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