☢ test - Í

and Collins (March 7, 2006), below, where, as here, the officer “did not testify that the housing development was occupied by low and moderate-income families.” Accord, Williams v. State , 303 Ga.App. 222, 692 S.E.2d 820 (March 29, 2010) (“The state's witnesses testified that Williams's residence was located in a housing project, commonly known as Jones Village, and made reference that there were multiple apartments at the location. Significantly, however, there was no evidence establishing that the housing project was publicly owned or operated. Nor was there testimony that the housing project was occupied by low and moderate-income families.”); Quarterman v. State , 305 Ga.App. 686, 700 S.E.2d 674 (August 26, 2010) (same as Williams ); Cantrell v. State , 316 Ga.App. 290, 728 S.E.2d 913 (June 20, 2012) (no evidence housing complex occupied by low and moderate-income families); Cooper v. State , 324 Ga.App. 451, 751 S.E.2d 102 (November 4, 2013) (no evidence apartments were “owned or operated by a public housing authority”). Hamilton v. State, 293 Ga.App. 297, 666 S.E.2d 630 (August 14, 2008). Evidence was sufficient to support defendant’s conviction for possession of cocaine with intent to distribute within 1000 feet of publicly operated housing project. “Evidence sufficient to show possession with the intent to distribute within 1,000 feet of a housing project includes testimony of police officers familiar with the area and expressly assigned to patrol public housing areas, Menefee v. State, 226 Ga.App. 725, 727(2) (487 S.E.2d 489) (1997), and testimony that the defendant's actions took place within 1,000 feet of a housing project. Haywood v. State, 248 Ga.App. 210, 212(2) (546 S.E.2d 325) (2001). The evidence showed that the arresting officers, who were conducting surveillance of an area of housing projects, testified that Hamilton's vehicle was stopped within 1,000 feet of a housing project.” Collins v. State, 278 Ga.App. 103, 628 S.E.2d 148 (March 7, 2006). Conviction for selling cocaine within 1,000 feet of a public housing project reversed for insufficient evidence; identifying property as “the Housing Authority” was insufficient to establish that it was a “housing project” was required by OCGA § 16-13-32.5(b). “[U]nder this evidence, the property could have been the administrative offices of the Housing Authority,” or “could have unoccupied altogether with no improvements thereon.” Citing Johnson v. State , 214 Ga.App. 77, 447 S.E.2d 74 (1994). Mikell v. State, 270 Ga. 467, 510 S.E.2d 523 (January 11, 1999). Reverses 231 Ga.App. 85, 498 S.E.2d 2d 531 (1998). Defendant was convicted for his second offense of selling drugs near a public housing project. Held, trial court erred in finding that it was required to enter maximum sentence under general recidivist sentencing statute, OCGA § 17-10-7(a). “OCGA § 16-13-32.5(c)(2) contains a separate provision setting forth the mandatory range of punishment for ‘a second or subsequent conviction under OCGA § 16-13-32.5(b). Thus, while the legislature directed that a second offender must be sentenced under subsection (c)(2), it also vested the sentencing court with discretion in determining the length of the sentence within the specified statutory range.” Later-enacted specific provision prevails over general recidivist provision. Citing Jenkins v. State , 265 Ga. 539, 458 S.E.2d 477 (1995). 15. TRAFFICKING IN DRUGS Crider v. State, 336 Ga.App. 83, 783 S.E.2d 682 (March 7, 2016). Methamphetamine trafficking and related convictions affirmed; evidence supported conviction where the amount of meth found under Crider’s car seat (7.36 grams) and in his motel room (23.51 grams) combined exceeded the weight required for trafficking under the statute at that time (28 grams). Brown v. State, 334 Ga.App. 674, 780 S.E.2d 372 (November 18, 2015). Physical precedent only; circumstantial evidence supported conviction for trafficking in methamphetamine: after a car wreck, a firefighter found a box containing 433 grams of crystal meth among the car debris. Brown, the driver, was seen “walking with his head down near the wrecked car ‘looking for something on the ground’” and also re-entered the still-smoking, overturned vehicle. “In this case, in light of the totality of the evidence, including Brown’s behavior at the scene of the wreck, the jury could conclude that it was not a reasonable hypothesis that Brown did not have personal knowledge of the contents of the box. And because the amount of methamphetamine was over 15 times the threshold trafficking amount , and in light of the similar transaction evidence from which a trier of fact could infer Brown’s knowledge of the drug trade, the evidence was sufficient to establish beyond a reasonable doubt that Brown knew that he possessed 28 grams or more of a mixture containing methamphetamine,” citing Summerville (June 26, 2015), below. Bennett v. State, 334 Ga.App. 381, 779 S.E.2d 420 (November 10, 2015). Methamphetamine trafficking and related convictions affirmed; “trafficking in methamphetamine in a quantity of 200 or more grams is a lesser included offense of trafficking in methamphetamine in a quantity of 400 or more grams, because proof of the former is necessarily included in the latter (i.e., a defendant cannot possess 400 or more grams without possessing 200 or more grams).”