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affirmed; trial court properly declined to charge on right to resist an unlawful arrest, as “there is no evidence to support a conclusion that the attempted arrest by Winn-Dixie employees was unlawful.” Contrary to defendant’s argument, store manager was authorized to make an arrest because the shoplifting offense occurred “within his immediate knowledge” even though he didn’t see it. “Merneigh's argument ignores the fact that the crime did occur within the presence of the food manager, one of the two persons attempting the arrest, and it occurred within the immediate knowledge of the store manager. OCGA § 17-4-60 provides, in pertinent part, that a private citizen may arrest an offender ‘if the offense is committed in his presence or within his immediate knowledge.’ (Emphasis supplied.) It does not distinguish between misdemeanor and felony offenses. The term ‘within his immediate knowledge’ enables a private citizen to use any of his senses to obtain knowledge that an offense is being committed. State v. Folk, 238 Ga.App. 206, 208, 521 S.E.2d 194 (1999); Winn-Dixie Stores v. Nichols, 205 Ga.App. 308, 310-311(2), 422 S.E.2d 209 (1992). A private citizen is not required to actually be present when a misdemeanor offense occurs.” II. SELECTIVE PROSECUTION Mooney v. State, 266 Ga.App. 587, 597 S.E.2d 589 (March 25, 2004). Child molestation and related convictions affirme. “Mooney contends that the trial court erred by denying his motion to dismiss the indictment on the basis of selective prosecution by the state. A defendant has the burden of proving, by the weight of the evidence, that his prosecution represents an ‘intentional or purposeful discrimination which is deliberately based upon an unjustifiable standard, such as race, religion, or other arbitrary classifications.’ A showing that others were not prosecuted for doing what the defendant allegedly did is not, in itself, sufficient to establish selective prosecution. A defendant must further show, through the testimony of the district attorney or otherwise, the extent of other investigations or prosecutions of those who allegedly committed similar offenses. If it appears that, despite knowledge of apparently similar offenses, the district attorney conducted little or no investigation into those offenses or initiated no prosecutions of any such offenses, the district attorney must then demonstrate that the defendant's prosecution is something other than selective prosecution. The trial judge as trier of fact might find that similar offenses have gone uninvestigated or unprosecuted, that the district attorney knew or should have known of such offenses, and that failure to act was without a reasonable and responsible explanation,” citing State v. Agan , 259 Ga. 541, 384 S.E.2d 863 (1989). No showing of selective prosecution by pointing to failure to prosecute unknown individuals; or by failure to prosecute individuals committing offenses different from defendant; or where defendant has failed to establish any arbitrary classifications. Accord, Sallee v. State , 329 Ga.App. 612, 765 S.E.2d 758 (November 13, 2014) (“There is no evidence that Sallee was prosecuted based on his race, religion, or other arbitrary classification.”); Randolph v. State , 334 Ga.App. 475, 780 S.E.2d 19 (November 13, 2015) (“Randolph has neither alleged nor shown that he was singled out on the basis of any arbitrary classification.”). JJ. SELF-DEFENSE See also subheadings IMMUNITY and JUSTIFICATION, above, and JURIES AND JURORS – CHARGE – SELF-DEFENSE, below Agyemang v. State, 334 Ga.App. 137, 778 S.E.2d 387 (October 8, 2015). Physical precedent only on this point. Simple battery conviction vacated and remanded for new trial. Trial court abused its discretion in excluding prior difficulties evidence proffered by defendant to show that victim was the aggressor. Husband (defendant) and wife fought; evidence was uncontroverted that wife hit husband first, but she “testified that she ‘had to hit him’ to express her frustration at his act of dropping [their special needs child and that] such hitting was ‘normal’ for their relationship.” Husband testified that wife “started throwing punches in his face and hit him with a pail.” He sought to introduce evidence of wife’s “history of unprovoked violence” toward him, which the trial court denied. Held, this was an abuse of discretion; contrary to trial court’s ruling, the evidence was not substantially more prejudicial than probative, especially considering wife’s admission “at trial that she had hit Agyemang in the past after disagreements in their marriage and that she was the initial aggressor during the present incident. In light of such evidence, it would not be unfairly prejudicial to allow the jury to hear of specific acts of violence she committed towards her husband in the past. … Further, the evidence of prior difficulties was probative for its impeachment value. [Wife] testified that although she first hit Agyemang, that such hitting was not forceful.” Although defendant contended that any contact by him with victim was accidental, he also set forth a prima facie case of self-defense based on wife’s own testimony “that she struck him first and that her act of striking him had nothing to do with any act of aggression on the part of Agyemang. He also relies upon his own testimony that he struck her only in his attempt to defend himself from his wife’s blows.” “See Turner v. State, 262 Ga. 359, 361(2)(c), 418 S.E.2d 352 (1992) (‘There is no hard and fast rule ... that the law of accident and of self defense are always “mutually exclusive”’).” Pena v. State, 297 Ga. 418, 774 S.E.2d 652 (June 29, 2015). Malice murder and related convictions affirmed. Trial court properly disallowed evidence of childhood abuse of defendant as part of a justification defense “based on battered person