supplied). 33 See Curry v. State, 238 Ga. App. 511, 522 (5) (c) (519 SE2d 269) (1999); see also Humphreys v. State, 253 Ga. App. 344, 346 (559 SE2d 99) (2002) (noting that final element of the crime “require[s] proof only that [the defendant] was even momentarily within arm’s reach of the gun” (citation and punctuation omitted)); Gibson v. State, 223 Ga. App. 103, 103 (1) (476 SE2d 863) (1996) (same). 34 See Clyde v. State, 298 Ga. App. 283, 285-86 (2) (680 SE2d 146) (2009) (“[The defendant’s] conviction cannot be sustained unless there was evidence that he had immediate access to the weapon. . . .”); Carswell, 251 Ga. App. at 736 (“[I]mmediate access to the weapon ... is required to sustain a conviction under OCGA § 16-11-106 (b).”). 35 Compare Carswell, 251 Ga. App. at 735-36 (1) (b) (<HOLDING>) with Gibson, 223 Ga. App. at 103 (1) (holding
holding anticipatory warrant for search of defendants home was invalid when defendant was required to pick up suitcase containing contraband at airport and there was no assurance at time warrant was issued that defendant would take suitcase to his home holding that circumstantial evidence was insufficient to sustain conviction when firearm was inside a zippered compartment of a suitcase which could have been zipped the entire time the defendant was in possession of   cocaine holding that circumstantial evidence alone is sufficient to support a cocaine conspiracy conviction holding similar evidence sufficient to sustain a jury verdict of possession with intent to distribute cocaine holding conviction for possession was supported by sufficient evidence when a firearm was found under the passenger seat where the defendant had been sitting and the arresting officer observed the defendant trying to place something in the glove compartment which when searched yielded an ammunition clip matching the gun under the seat