DILLARD, Presiding Judge.

Following a bench trial, Marlin Bibbs was convicted of possessing a firearm as a convicted felon. Bibbs appeals from this conviction, arguing that (1) the evidence was insufficient to sustain it, and (2) the court erred in denying his motion to suppress evidence when the search warrant lacked probable cause and was overly broad in scope. For the following reasons, we affirm.

Viewed in the light most favorable to the trial court’s judgment,1 the record shows that on October 13, 2020, Illinois State Police conducted a traffic stop of a a Pixel cell phone—depicted a child in blue-and-green underwear lying on a bed with a red blanket and blue sheets with white New York Giants logos. The GPS coordinates for this third digital photo corresponded to the address of 1209 Richmond Ridge, Loganville, Walton County, Georgia 30052—the same address belonging to De Jesus- Merced’s minor passenger.

Given what was discovered during De Jesus-Merced’s traffic stop, a deputy with the Walton County Sheriff’s Office in Georgia took out a search warrant for the Loganville address. And in addition to providing the above facts, the search warrant affidavit also noted the deputy’s belief that there was probable cause to search the address for evidence related to human trafficking, sodomy, aggravated child molestation, enticing a minor for indecent purposes, sexual battery, and sexual exploitation of children. A search warrant was then issued to look for the blue New York Giants bed sheets and “electronic media capable of storing digital imag[es] (to be searched by qualified personnel).”3 Law enforcement then went to the Loganville address, where they found Bibbs and two women—Amber Bey and Doris Bibbs. And while conducting the search, officers discovered several firearms and ammunition. They also learned that Marlin Bibbs was a convicted felon. As a result, the firearms and ammunition were collected. The firearms included an AR-style rifle located in plain view on the floor near the lefthand side of the bed in the primary bedroom; a bag of ammunition on the floor under the same bed; and a holstered revolver found between the bed’s mattress and box springs on the lefthand side. And within the same bedroom were personal items belonging to Bibbs—including his passport, social-security card, and insurance documents showing that he lived at that address. These and other items were found in a night stand on the lefthand side of the bed, in dressers, and in boxes. All of the items—including the firearms—were found while law enforcement searched for electronic media, which can vary in size and be hidden inside other items (such as books).4

Bibbs was later indicted on one count of possession of a firearm as a convicted felon because he “knowingly and without lawful authority[ ] possess[ed] a Sig Sauer 9 mm pistol, a Charter Arms 9mm revolver, and a Radical Firearms rifle, firearms, accused having been convicted of a felony offense . . . on May 30, 2000 . . . .” As to the Sig Sauer 9mm pistol, before the bench trial, the State and Bibbs stipulated to the following facts: “In the master bedroom of the residence, [law enforcement] discovered a handbag resting on top of the chest of drawers on the right side of the bedroom . . . . This is a purse that belongs to Amber Bey. Found inside that purse was a Sig Sauer Pistol, P365, serial number 66A806550.” The parties also stipulated that the driver’s license inside the purse belonged to Bey, and that Bey purchased or acquired the three firearms.

Bibbs filed a pretrial motion to suppress the evidence discovered as a result of the search warrant, arguing that law enforcement lacked probable cause to search the residence and the warrant was overly broad in scope. The trial court ultimately denied the motion to suppress, concluding that the search warrant established a sufficient nexus between the images located on the iPhone in Illinois and the requested search location in Georgia. In doing so, the trial court pointed to the meta data linking the photos to the house—i.e., the GPS coordinates for the photo of a child wearing only underwear and lying on a bed with the same sheets as those pictured in one of the child pornography photos. Additionally, the address for the GPS coordinates belonged to the minor child who was in the car stopped in Illinois, which was driven by a convicted child-sex offender in possession of child pornography. And as for the scope of the warrant, as it related to allowing a search for “electronic media capable of storing digital imag[es],” the trial court concluded the magistrate court was allowed to “make a pragmatic, common-sense decision that there was a fair probability that more evidence of child molestation would be found on digital devices at the Richmond Ridge residence.” Thus, the court denied the motion to suppress.

The bench trial ensued, and at its conclusion, the trial court found Bibbs “had constructive possession over at least two of the firearms in the bedroom” when they were located on the lefthand side of the room along with sensitive personal items belonging to him (e.g., his Social Security card, passport, insurance documents). These personal items, the court concluded, suggested Bibbs’s routine access to the lefthand side of the bed where two of the three firearms were located. Bibbs now appeals from both his conviction and the court’s denial of his motion to suppress.

1. Bibbs first argues the evidence was insufficient to sustain his conviction for possession of a firearm as a convicted felon. We disagree.

On appeal from a criminal conviction, we view the evidence “in the light most favorable to the verdict and an appellant no longer enjoys the presumption of innocence.”5 We must determine whether the evidence is sufficient under the standard of Jackson v. Virginia,6 and in doing so, we do not weigh the evidence or determine witness credibility.^[7] Thus, any conflicts or inconsistencies in the evidence were for the trial court to resolve as the finder of fact.^[8] And so long as there is some competent evidence—even though contradicted—to support each fact necessary to make out the State’s case, we will uphold the verdict.^[9]

Turning to this case, under Georgia law, “[a]ny person . . . who has been convicted of a felony by a court of this state or any other state . . . who receives, possesses, or transports any firearm commits a felony . . . .”10 And possession of a firearm can be “either actual or constructive.”11 Importantly, a person constructively possesses an item when, “though not in actual possession, he knowingly has both the power and the intention at a given time to exercise dominion or control” over the item.^[12] So, while constructive possession can be shown by circumstantial evidence, “as with any charge based on purely circumstantial evidence, in order to support a conviction, the evidence must exclude every reasonable hypothesis, save that of constructive possession by the defendant.”13 Finally, whether the evidence “shows something more than mere presence or proximity, and whether it excludes every other reasonable hypothesis, are questions committed principally to the trier of fact, and we should not disturb the decisions of the trier of fact about these things unless they cannot be supported as a matter of law.”14

Here, the State presented sufficient evidence to show that Bibbs constructively possessed the rifle and revolver found on the lefthand side of the bed in the primary bedroom—the rifle being in plain view in the corner of the room and the revolver tucked between the mattress and box springs. And on that same side of the bedroom were numerous sensitive documents belonging to Bibbs, including his social-security card, passport, and several files containing insurance documentation revealing that he lived at the address. To be sure, two other individuals—Amber Bey and Doris Bibbs—were also at the residence when it was searched; but the location of personal documents within the primary bedroom strongly supports the inference that Bibbs had access to the areas where the firearms were found—one being in plain view—and he used that part of the room to store his belongings.^[15] This enumerated error, then, lacks merit.

2. Next, Bibbs challenges the trial court’s denial of his motion to suppress evidence discovered due to the executed search warrant. In doing so, he contends the search warrant (a) lacked probable cause and (b) was overly broad in scope with reference to “electronic media.” We will consider each of these arguments in turn.

(a) Probable Cause. Bibbs begins by claiming the search warrant lacked probable cause. We disagree.

Under the Fourth Amendment to the United States Constitution,16 a search warrant in Georgia may be issued only on “facts sufficient to show probable cause that a crime is being committed or has been committed . . . .”17 And when the judge who issues a warrant determines whether probable cause exists, they must

make a practical, common-sense decision whether, given all the circumstances set forth in the affidavit before [them], including the “veracity’‘ and ‘’basis of knowledge’‘ of persons supplying hearsay information, there is a fair probability that contraband or evidence of a crime will be found in a particular place.^[18] Our duty, then, is to review the issuing judge’s decision to determine whether there was a “substantial basis” for concluding that “probable cause existed to issue the search warrant[ ].”19 And as a reviewing court, we give substantial deference to the finding of probable cause.^[20] Indeed, the test for probable cause is “not a hypertechnical one to be employed by legal technicians, but is based on the ‘factual and practical considerations of everyday life on which reasonable and prudent men act.’”21 So, in making this determination, the judge “may draw reasonable inferences

(2022); see Pugh v. State, 318 Ga. 706, 714 (2) (a) (899 SE2d 653) (2024) (“Considering the totality of the circumstances outlined in the affidavit, the magistrate was authorized to make certain common-sense conclusions about human behavior, and infer that [defendant] was somehow involved in [victim’s] murder, that evidence of his location and communications in the time surrounding the murder might be found in his cell phone records, and that the target phone number belonged to [defendant].” (punctuation and citations omitted)).

from the material supplied . . . by applicants for a warrant.”22 Thus, even “doubtful cases” should be “resolved in favor of upholding a warrant.”23

Here, Bibbs argues the State failed to establish a connection or nexus between the Loganville residence and the items that were sought—i.e., the blue New York Giants bed sheets and “electronic media capable of storing digital images.” More precisely, he contends the affidavit in support of the warrant “did not indicate that these items would be considered evidence of the alleged crimes” and failed to link the items to the crimes—which again were human trafficking, sodomy, aggravated child molestation, enticing a minor for indecent purposes, sexual battery, and sexual exploitation of children. He also claims there was no indication within the affidavit that people who commit such crimes “often store evidence of the crimes, such as photographs and videos, on digital media.” And finally, he maintains the affidavit lacked a justification or explanation for why the Loganville address needed to be searched for the items.

We reject each of Bibbs’s contentions. The magistrate judge who issued the search warrant was justified in concluding that there was a fair probability the described bed sheets and devices capable of storing electronic images would be located at the Loganville address. As detailed above, De Jesus-Merced—a convicted child-sex offender—was traveling with an unrelated minor who lived at the Loganville address. And during a search of the convicted sex offender’s iPhone, law enforcement found two images of an adult male penis penetrating a child’s anus (the production of which was an act of sexual exploitation of children,24 and which depicted acts of aggravated child molestation,25 sodomy,26 and sexual battery27). In one of the photos, blue bed sheets with a white type-print logo were visible. A third image depicted a child wearing only underwear lying on a bed with blue sheets that had white New York Giants logos. And the GPS coordinates for this third digital photo corresponded to the address of 1209 Richmond Ridge, Loganville, Walton County, Georgia 30052, which indicated the photograph was taken at that location.

Given the foregoing, the foundation for the search warrant was not based on mere suspicion.^[28] Indeed, considering the totality of the circumstances (and the substantial deference we must give to the judge who issued the search warrant), a sufficient nexus was established between the items law enforcement sought to locate, the suspected crimes, and the Loganville residence.^[29] (b) The Particularity Requirement. Bibbs next contends the trial court erred in denying his motion to suppress when the search warrant was overly broad and lacked particularity because it permitted officers to search for “electronic media capable of storing digital imag[es] (to be searched by qualified personnel).” Again, we disagree.

The Fourth Amendment provides that “no Warrants shall issue, but upon probable cause, supported by Oath or affirmation, and particularly describing the place to be searched, and the . . . things to be seized.”30 And in this sense, we have explained that “although a warrant cannot leave the determination of what articles fall within its description and are to be seized entirely to the judgment and opinion of the officer executing the warrant, the degree of specificity in the description is flexible and will vary with the circumstances involved.”31 To that end, the “particularity requirement” only demands that “the executing officer be able to identify the property sought with reasonable certainty.”32

Even so, Bibbs takes issue with the search warrant affidavit’s failure to “list the owners of the house or who might reside there or whether there was any reason to believe the house contained electronic media.” But this contention is a nonstarter. As the Supreme Court of the United States has explained, search warrants are “not directed at persons; they authorize the search of ‘places’ and the seizure of ‘things,’ and as a constitutional matter they need not even name the person from whom the things will be seized.”33 Bibbs also complains that there was no language “limiting the search to electronic media capable of storing digital images relevant to the crimes alleged.” But as explained above, the search warrant and supporting affidavit established a nexus between the suspected crimes, the address in question, and the items law enforcement sought to locate (i.e., the bed sheets and “electronic media capable of storing digital images”).

As to the final part of Bibbs’s argument (i.e., that the search warrant did not clearly limit what law enforcement could search for within the electronic devices once seized),34 this is of no consequence for the items he seeks to suppress. First, officers

(physical precedent only).

were limited to searching for and seizing devices that were capable of storing digital images of the crimes alleged, but they were not permitted to seize devices incapable of storing digital images—for example, devices only capable of storing digital audio.^[35] And the circumstantial evidence of Bibbs’s possession of the firearms was found within the primary bedroom of the residence while officers searched for such devices; the evidence was not found within such devices.^[36] So, even if we were to assume the

phones.” (punctuation omitted)), with Westbrook v. State, 308 Ga. 92, 98 (3) (a) (839 SE2d 620) (2020) (holding that “the use of the phrase ‘electronic data’ was specific enough to enable a prudent officer to know to look for photographs and videos stored on [the defendant’s] cell phone”).

warrant was overly broad by its parenthetical inclusion that the seized devices were “to be search by qualified personnel,” there is no indication that a broader search occurred here when the officers located the firearms during a permissible search for the electronic devices.^[37] Likewise, our Supreme Court has explained that “the inclusion of overly broad provisions does not necessarily doom the warrant in its entirety” because “the warrant can be cured by redaction, that is, by striking from the warrant those severable phrases and clauses that are invalid for lack of probable cause or generality and preserving those severable phrases and clauses that satisfy the Fourth Amendment.”38 The trial court properly denied, then, Bibbs’s motion to suppress on this ground.

For all these reasons, we affirm the trial court’s judgment.

Judgment affirmed. Mercier, C. J., and Land, J., concur.