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863) (1980) (a probation “condition requiring the probationer to submit to polygraph tests does not violate the [probationer's] Fifth Amendment rights.”). Different result if revocation based on assertion of privilege as to specific questions. Jones v. State, 314 Ga.App. 442, 724 S.E.2d 454 (February 29, 2012). Probation revocation reversed; trial court couldn’t revoke probation based on a violation not set out in the petition to revoke. Here, petition alleged that defendant failed to report to probation, but revocation was based on failure to register as a sex offender – a special condition of defendant’s probation (for cruelty to children) not mentioned in the revocation petition. “‘Due process requires that a defendant be given written notice of the claimed violation of his probation prior to [a probation] revocation hearing. In addition, in order to revoke the probationary features of a sentence the defendant must have notice and opportunity to be heard, the notice being sufficient to inform him not only of the time and place of the hearing and the fact that revocation is sought, but the grounds upon which it is based. It may not be revoked where there is no evidence that the defendant violated its terms in the manner charged in the notice, even though there be evidence at the hearing that the defendant violated the terms of probation in some other manner as to which there was no notice given. Likewise, if a judgment is based upon an offense not charged in the petition for revocation, it must be reversed.’ (Citations and punctuation omitted.) Kitchens v. State, 234 Ga.App. 785, 787–788(2) (508 S.E.2d 176) (1998).” Gray v. State, 313 Ga.App. 470, 722 S.E.2d 98 (December 29, 2011). Evidence didn’t support superior court’s revocation of defendant’s probation. 1. Evidence didn’t support finding that defendant possessed marijuana found in residence. Police executing search warrant at drug dealer’s residence found Gray there; no evidence indicated that Gray lived there. Gray was seated near open front door, said he didn’t live there, and was just there to get his gaming console from residents. Officers found 1.9 grams of marijuana in a sandwich bag inside a black plastic bag in a bedroom closet. “‘A finding of constructive possession of contraband cannot rest upon mere spatial proximity to the contraband, especially where, as here, the contraband is hidden. [Cits.]’ Mitchell v. State, 268 Ga. 592, 593 (492 S.E.2d 204) (1997). And ‘[e]vidence merely showing that contraband was found in a residence occupied by the defendant is not sufficient to support a conviction, especially where other persons had equal access to the contraband and therefore an equal opportunity to commit the offense.’ (Citation and footnote omitted.) Johnson v. State, 282 Ga.App. 52, 54(1) (637 S.E.2d 775) (2006). The same rule applies in a probation revocation. See Brown v. State, 294 Ga.App. 1, 5–6(2) (668 S.E.2d 490) (2008) (evidence that probationer sitting outside house and cocaine visible through glass storm door slight evidence of possession but not preponderance sufficient to revoke probation); Anderson v. State, 212 Ga.App. 329, 329–330 (442 S.E.2d 268) (1994) (defendant's presence in mother's house when drugs found in her bedroom slight evidence of possession but not preponderance). Here, the State showed only that Gray was at the open front door of a trailer and that a sandwich bag of marijuana was found in a closed container inside a closet in a bedroom. The evidence showed that other individuals had access to the trailer, including a man who sold drugs to the confidential informant. While the State contends that Gray's ‘claimed ownership of some of the personal property found at the residence’ supports a finding of constructive possession, under the evidence presented here, that claim did not demonstrate Gray's residence at the trailer to the exclusion of any other reasonable hypothesis. Ordinarily, property supporting an inference of residence for the purposes of constructive possession consists of clothing, banking or business records, or other personal items customarily kept in ones living quarters. See, e.g. Cox v. State, 300 Ga.App. 109, 110 (684 S.E.2d 147) (2009) (bedroom night stand contained many items with defendant's name on them, including paperwork, insurance documents and several picture identification cards); Aguey–Zinsou v. State, 296 Ga.App. 319, 324(2) (674 S.E.2d 366) (2009) (bank statement, bill, and envelope all bearing appellant's name and address found in bedroom at that address); McWhorter v. State, 275 Ga.App. 624, 626(1) (621 S.E.2d 571) (2005) (personal items found in bedroom with methamphetamine manufacturing equipment included prescription bottle, notebook, letters, and handgun); Daniels v. State, 192 Ga.App. 446(1) (385 S.E.2d 107) (1989) (men's clothing as well as business records and cancelled checks of two businesses owned by appellant found in apartment leased to appellant's girlfriend). A video game console, while possibly ‘worth a great deal of amount of money’ as the State contended, is not, without more, a personal item of this kind.” 2. Defendant’s probation couldn’t be revoked based on failure to attend counseling where he was prevented from attending by his unjustified arrest. Defendant had been attending, but “he was involuntarily removed from the program as a result of his arrest and that he had no ‘opportunity to address the arrest until his revocation hearing.’ As we note … above, the evidence was insufficient to show that Gray committed the offense for which he was arrested. It follows that ‘his own actions’ did not cause him to be dismissed from the drug treatment program, and he therefore was not in ‘willful and voluntary’ violation of his probation.” Gaddis v. State, 310 Ga.App. 189, 712 S.E.2d 599 (June 20, 2011). Probation revocation affirmed; trial court properly admitted evidence of OnTrak TesTstik, both based on expert opinion and judicial notice of other Georgia court decisions.