Thomas Reed Roberts v. Commonwealth of Virginia, 1265162

Officer Duane saw a roll-call photo of a recent Chesterfield County robbery suspect and later observed Roberts at a nearby motel in a high‑crime area; the officer thought Roberts resembled the photo.
Duane, parked about eight feet from Roberts, asked if Roberts was staying at the motel and if he had ID; Roberts answered no and began to walk away when Duane exited his car to approach.
Roberts fled on foot when Duane approached; after a ~90‑second chase the officer caught and handcuffed him.
When detained, Roberts was clutching a marble‑sized folded piece of a lottery ticket; Duane recognized the fold as a common packaging for drugs, opened it, and observed off‑white rock later identified as cocaine; Roberts said aloud, “It’s just one hit.”
Duane’s database check shortly thereafter showed Roberts was not the robbery suspect but had outstanding felony warrants.
Roberts entered a conditional guilty plea to possession of cocaine, preserving his right to appeal the denial of his motion to suppress; the trial court denied suppression and the Court of Appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether initial contact was a Fourth Amendment seizure	Duane’s questioning and approach were a show of authority constituting a seizure	The contact was consensual non‑coercive questioning in public	Not a seizure — officer’s initial questions from car were non‑coercive
Whether flight and circumstances justified detention/handcuffing	Handcuffing converted the encounter into an unsupported arrest	Officer had reasonable, articulable suspicion (match to suspect, trespass signs, flight); handcuffs were reasonable	Stop and brief detention were supported by reasonable suspicion; handcuffs did not convert stop into arrest
Whether the folded lottery ticket could be lawfully seized/searched without a warrant	A folded lottery ticket is a legal item; Grandison requires more than folding to justify search	Totality (match to robbery suspect, high‑crime area, trespass, headlong flight, clutching small folded piece) gave probable cause	Opening the folded ticket was supported by probable cause; search was reasonable
Whether officer’s observations and statements supported arrest	Officer lacked probable cause to arrest before search	After viewing contents and hearing spontaneous admission, officer had probable cause	Probable cause existed to arrest after the ticket was opened and substance observed plus statement

Whitfield v. Commonwealth, 265 Va. 358 (4th Cir. 2003) (burden and standards for warrantless search challenges in suppression context)
Grandison v. Commonwealth, 274 Va. 316 (Va. 2007) (folded currency alone insufficient for probable cause)
Florida v. Bostick, 501 U.S. 429 (U.S. 1991) (consensual encounters vs. seizures; reasonable person free‑to‑leave test)
Illinois v. Wardlow, 528 U.S. 119 (U.S. 2000) (unprovoked flight in high‑crime area supports reasonable suspicion)
Ornelas v. United States, 517 U.S. 690 (U.S. 1996) (probable cause assessed under totality of circumstances; de novo review)
McGee v. Commonwealth, 25 Va. App. 193 (Va. Ct. App. 1997) (appellate deference to trial court’s factual findings and inferences)