Cordon v. Com., 701 S.E.2d 803

Detective Baer executed a search warrant at 169 Finley Square in Hampton; Cordon was not present, but his uncle owned the house and lived there.
A cooler in a bedroom contained two bags of suspected powder cocaine; one bag weighed 5.001 grams.
Bedroom drawers and nightstand contained items bearing Cordon's name, including checks, papers, a business card, and drug paraphernalia.
Cordon admitted the room was his during prior investigations and described the bedroom as his; he later denied living there when questioned.
Baer found his business card in the nightstand drawer beside drug paraphernalia; Cordon had been given the card two days earlier during a burglary investigation.
Cordon was charged with possession of cocaine under Code § 18.2-250 and convicted; on appeal, the Court of Appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for constructive possession	Cordon's denial and occupancy of the room showed guilt beyond reasonable doubt	Circumstantial links were insufficient to prove knowledge and dominion	Conviction reversed; insufficient evidence of constructive possession
Role of denials and surrounding facts in proving guilt	Evidence, including occupancy claims and items in the room, supports knowing possession	Denials and lack of direct link to the cooler undermine possession finding	Evidence insufficient beyond reasonable doubt; reversing Court of Appeals judgment

Rawls v. Commonwealth, 272 Va. 334 (2006) (presence in room with contraband supports possession; corroborating factors)
Lane v. Commonwealth, 223 Va. 713 (1982) (owner/occupant; denial of knowledge supports guilt when accompanied by other links)
Rogers v. Commonwealth, 242 Va. 307 (1991) (circumstantial evidence must exclude reasonable hypotheses of innocence)
Inge v. Commonwealth, 217 Va. 360 (1976) (constructive possession analysis framework)
Covil v. Commonwealth, 268 Va. 692 (2004) (false or evasive account as evidence of guilty knowledge)
Maxwell v. Commonwealth, 275 Va. 437 (2008) (standard for reviewing sufficiency of evidence aligns with Jackson v. Virginia)
Jackson v. Virginia, 443 U.S. 307 (1979) (beyond a reasonable doubt standard for appellate review of sufficiency)
Drew v. Commonwealth, 230 Va. 471 (1986) (standard for evaluating circumstantial evidence")
Schneider v. Commonwealth, 230 Va. 379 (1985) (preserving deference to trial court factual findings)
Young v. Commonwealth, 275 Va. 587 (2008) (credibility and weight of witness testimony rested with fact-finder)