Derek Lamont Porter v. Commonwealth of Virginia, 0631161

At ~10:00 p.m. in a known high-narcotics area, Officer Parrish approached Porter in a parked car after illuminating it with a patrol spotlight. Parrish spoke with Porter, who appeared "extremely nervous."
Porter produced his driver's license and handed two prescription pill bottles to Parrish after the officer asked to “see” them; one bottle was labeled morphine and marked a controlled substance.
The morphine bottle had been filled seven days earlier with 90 pills but contained only two; Porter said his dose was "two to three pills a day," suggesting many pills were missing.
Parrish requested backup and, during the subsequent interaction, Porter admitted selling the missing morphine pills. Porter was charged with possession with intent to distribute.
Porter moved to suppress, arguing the encounter became a seizure when Parrish used the spotlight and that Parrish exceeded the scope of consent by "searching" the bottle; the trial court denied the motion. Porter pleaded conditional guilty and appealed.

Issue	Plaintiff's Argument (Porter)	Defendant's Argument (Commonwealth)	Held
Whether Parrish exceeded scope of consent by inspecting the morphine bottle	Porter: He consented only to show bottles, not to a search inside the bottle; inspection exceeded consent	Commonwealth: Porter failed to preserve this argument below; argument is procedurally barred	The claim is barred under Rule 5A:18; appellate court did not reach the merits
Whether encounter became unlawful seizure when officer viewed label and inside the bottle and then detained Porter	Porter: Once the bottle was identified as his, detention should have ended; no reasonable suspicion remained	Commonwealth: Totals of circumstances (high-crime area, late hour, nervousness, large discrepancy in pill count) gave reasonable articulable suspicion for investigative stop	Court held the officer had reasonable articulable suspicion; detention was valid

Terry v. Ohio, 392 U.S. 1 (1968) (standard for investigative stops)
Illinois v. Wardlow, 528 U.S. 119 (2000) (nervous behavior in high-crime area is relevant to reasonable suspicion)
Arizona v. Arvizu, 534 U.S. 266 (2002) (totality-of-circumstances approach to reasonable suspicion)
Harris v. Commonwealth, 276 Va. 689 (Va. 2008) (appellant bears burden to show suppression ruling was reversible error)
Edwards v. Commonwealth, 41 Va. App. 752 (Va. Ct. App. 2003) (preservation rule: one argument does not preserve a different legal point)
Vaughn v. Commonwealth, 279 Va. 20 (Va. 2010) (failure to raise issue at trial prevents appellate review)
Raab v. Commonwealth, 50 Va. App. 577 (Va. Ct. App. 2007) (reasonable suspicion need not eliminate innocent explanations)
Whitaker v. Commonwealth, 279 Va. 268 (Va. 2010) (presence in high-crime area is a contextual factor in Terry analysis)