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proximity of the methamphetamine to the location where Bone fell to the ground, and Bone's statement to Officer Gravitt that he had exchanged drugs for use of the car.” Henry v. State, 311 Ga.App. 353, 716 S.E.2d 232 (August 3, 2011). Evidence supported defendant’s conviction for possession of marijuana. Defendant was driving vehicle owned by his girlfriend, who was a passenger. During traffic stop, officers “noticed a strong odor of marijuana coming from the vehicle, which the officer believed would have been noticeable to the vehicle's occupants. A green, leafy material later determined to be marijuana was found in the glove compartment.” “In cases involving contraband found in vehicles, the state is generally entitled to an evidentiary presumption that the driver or owner of the vehicle is in constructive possession of the contraband. [Cit.] And … the evidence of the odor of marijuana in the vehicle also supported a finding that Henry and [girlfriend] Smith jointly possessed the marijuana.” “ Because the evidence that Henry was the driver of the vehicle was not the sole evidence of his possession of the marijuana found therein, and because no evidence was presented that anyone other than Henry and Smith (the charged defendants) had equal access to the marijuana, the ‘equal access’ rule cited by Henry does not apply in this case. See State v. Johnson, 280 Ga. 511, 514, 630 S.E.2d 377 (2006) (‘equal access’ rule applies only where the sole evidence of possession of contraband found in the vehicle was the defendant's ownership or possession of the vehicle); Cabrera [ v. State, 303 Ga.App. 646, 651-652(1), 694 S.E.2d 720 (2010)] (defendant was not entitled to benefit of ‘equal access’ rule where state jointly charged both him and the only other occupant of a vehicle with possession of contraband found therein).” Bailey v. State, 311 Ga.App. 316, 715 S.E.2d 681 (June 29, 2011). Convictions for drug and firearm possession affirmed; evidence supported finding of possession. “Here, the State presented evidence of bills in Bailey's name for the residence, a poster on the bedroom door with Bailey's name, and Bailey's wallet found in the bedroom. Based on this evidence, the jury was entitled to find that Bailey lived in the residence and thus could infer that the contraband found inside was his.” Davenport v. State, 308 Ga.App. 140, 706 S.E.2d 757 (March 2, 2011). Defendants’ convictions for methamphetamine possession and related offenses affirmed; evidence supported conviction for possession of firearm during commission of crime. Criticizes cases using general law related to “possession” instead of the more restrictive language used in OCGA § 16-11-106(b): “The evidence must show that while committing or attempting to commit one of the specified crimes, one or more of the specified weapons was either on the defendant's person or within arm's reach of his person. See OCGA § 16-11-106(b). The inclusion of ‘within arm's reach’ in OCGA § 16-11-106(b) defines constructive possession for purposes of this statute and makes the proof of possession for purposes of the statute narrower than the proof sufficient to establish constructive possession of contraband or weapons in other contexts. See, e.g., OCGA § 16-11-131(b) (making it unlawful for convicted felons to receive, possess, or transport firearms); OCGA § 16-11-132(b) (‘[I]t shall be unlawful for any person under the age of 18 years to possess or have under such person's control a handgun .’); OCGA § 16-13-30(a) (making it unlawful to ‘purchase, possess, or have under ... control any controlled substance’). See generally In re: C.M., 290 Ga.App. 788, 791-92(2), 661 S.E.2d 598 (2008) (analyzing traditional constructive possession in sustaining conviction for possession of a firearm by a person under 18); Simpson v. State, 213 Ga.App. 143, 145(3), 444 S.E.2d 115 (1994) (analyzing traditional constructive possession and stating that this type of possession is sufficient to sustain conviction for possession of a firearm by a felon); Cantrell v. State, 204 Ga.App. 330, 331-32, 419 S.E.2d 141 (1992) (analyzing traditional constructive possession in sustaining conviction for possession of firearm by a felon and possession of cocaine). And to the extent that any of our prior opinions can possibly be read as suggesting otherwise, [fn: Some of our prior cases make no mention of the ‘within arm's reach’ component of the statute. See Boone [ v. State, 293 Ga.App. 654-657(1), 667 S.E.2d 880 (2008)] (upholding conviction without addressing whether evidence was sufficient to find that defendant was within arm's reach of firearm while committing underlying crimes); Howard v. State, 291 Ga.App. 289, 289-91(1), 661 S.E.2d 644 (2008) (same); Lopez v. State, 259 Ga.App. 720, 721- 22(1), 578 S.E.2d 304 (2003) (upholding conviction when passenger in car was ‘in joint constructive possession’ because he was ‘in a position to see the pistol ... [in] the glove box’); Taylor v. State, 263 Ga.App. 420, 420-22(1), 587 S.E.2d 791 (2003) (upholding conviction for pistol found under driver's seat but without analysis of the ‘within arm's reach’ component). Others appear to muddle the evidence necessary to find ‘possession’ under OCGA § 16-11-106(b) with that sufficient to sustain a conviction for possessing drugs or for possessing a weapon in other contexts. See Daugherty [ v. State, 283 Ga.App. 664, 667-668(1), 642 S.E.2d 345 (2007)] (upholding conviction for possession of firearm while committing felony and for possession of firearm by a convicted felon but only applying the constructive-possession standard that is sufficient to support the latter type of criminal possession); Allen v. State, 286 Ga.App. 469, 470(1), 649 S.E.2d 583 (2007) (upholding conviction under OCGA § 16-11-106(b) by applying the standard of joint constructive possession that is applicable to other contraband); Humphreys, 253 Ga.App. at 345, 559 S.E.2d 99 (upholding conviction under OCGA § 16-11-106(b) with mention of ‘within arm's reach’ component as the ‘final element’ of crime, but first

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