Sierra v. Commonwealth, 59 Va. App. 770

Sierra was convicted in a bench trial of possession of a controlled substance under Code § 18.2-250; eight pills were found on his person during a search after a DUI stop.
Two pills tested positive for methylphenidate (Concerta), a Schedule II substance; officer relied on pill shapes and numbers to classify them as prescription pills.
Sierra testified he believed the pills were aspirin or Tylenol and that he merely kept them in his pocket before performing.
The trial court rejected Sierra's credibility, finding he knew the pills were a controlled substance and not ordinary medication.
The Court of Appeals reviews the trial court’s findings of fact for plain error and defers to credibility determinations, while reviewing legal interpretations de novo.
The conviction is affirmed after analyzing the mens rea requirement of Code § 18.2-250 and the sufficiency of the evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does Code § 18.2-250 require knowing the exact substance?	Sierra argues he must know the exact substance.	Sierra contends knowledge of presence is insufficient.	No; knowledge of a controlled substance suffices.
Is there sufficient evidence Sierra knew he possessed a controlled substance?	Sierra asserts lack of precise substance knowledge defeats knowledge element.	Sierra’s credibility undermines his claim; pills apparent as prescription drugs.	Yes; evidence supports knowledge of possessing a controlled substance.

Burrell v. Commonwealth, 58 Va. App. 417 (2011) (trial court findings reviewed for clear error; rational on evidence)
Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency in criminal trials)
Young v. Commonwealth, 275 Va. 587 (2008) (discussed mens rea and knowledge of substance; distinguished case)
United States v. Barbosa, 271 F.3d 438 (2001) (possession of controlled substance sufficiency without knowing exact drug)
United States v. Martin, 274 F.3d 1208 (2001) (knowledge that substance is controlled suffices)