Antonio Mandell Morris v. Commonwealth of Virginia, 1144151

On April 24, 2014, deputies stopped Antonio Morris on U.S. Route 13 after dispatch reported the vehicle was impounded; Morris produced a receipt showing he had redeemed the car the prior day.
While Deputy Bailey continued to verify the impound status, Deputies Lewis and Pike arrived conducting highway drug-interdiction and announced they would perform a canine sniff; Morris refused to exit his vehicle.
As deputies began to deploy a drug dog, Morris drove away from the stop and led officers on a ~2-mile pursuit before being stopped by a blocking vehicle and arrested for eluding.
After the chase, deputies found a black plastic bag at a curve where Morris briefly lost control; it contained ~400 glassine packets later confirmed to contain ~136 grams of heroin.
Morris moved to suppress the heroin as the product of an unlawful extension of the traffic stop and was convicted (bench trial) of possession with intent to distribute heroin (second offense) and eluding; he appealed challenging sufficiency of the evidence and the denial of the suppression motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to prove knowing possession with intent to distribute heroin	Commonwealth: flight, dog alerts on vehicle, glove box open, bag found near curve where defendant lost control support constructive possession and knowledge	Morris: no fingerprints/DNA, no one saw him throw the bag, alternative hypothesis that someone else discarded the drugs	Held: Evidence sufficient — circumstantial evidence plus flight and location/condition of bag support reasonable inference Morris knowingly possessed and discarded the heroin
Whether the traffic stop was impermissibly extended (motion to suppress) under Rodriguez	Morris: once documents were produced and impound receipt shown, deputies lacked reasonable suspicion and the attempted canine sniff unlawfully prolonged the stop	Commonwealth: Bailey was still verifying vehicle status and possessed the documents; the stop was ongoing when other deputies arrived and the canine sniff was aborted by Morris’s flight; evidence was abandoned during flight, not the fruit of a seizure	Held: Denial of suppression affirmed — stop was not unreasonably extended and, in any event, the heroin was abandoned during flight (Hodari D. rule) and not subject to Fourth Amendment suppression

Rodriguez v. United States, 135 S. Ct. 1609 (2015) (officer may not prolong traffic stop for unrelated checks absent reasonable suspicion)
California v. Hodari D., 499 U.S. 621 (1991) (property discarded during flight before seizure is not the fruit of a Fourth Amendment seizure)
Illinois v. Caballes, 543 U.S. 405 (2005) (canine sniff during lawful traffic stop is not a search if it does not prolong the stop)
Jones v. Commonwealth, 279 Va. 52 (Va. 2010) (flight may be considered as consciousness of guilt)
Young v. Commonwealth, 275 Va. 587 (Va. 2008) (elements for proving knowledge in drug possession cases)