Wayne Antonio Bland, Jr. v. Commonwealth of Virginia, 785 S.E.2d 798

Appellant Wayne Antonio Bland was indicted for possession of a firearm after a felony conviction; he moved to suppress a gun seized after a police encounter and was denied; convicted after a bench trial and sentenced to five years.
A 911 caller told Richmond dispatch (within ~2 minutes of events) she saw an African‑American man in a tan hat, orange/white striped shirt, and tan cargo shorts brandish a gun near children, then walk on Redd Street and place the gun in his pocket.
Officers Butler and May arrived ~2 minutes after the call, found a man matching the description on Redd Street (Bland).
As officers approached, Bland patted his front and rear right pockets and pulled his shirt down over his right side (officers characterized this as a "weapons check").
Officers announced the tip and expressed intent to pat him down; Bland pushed the officer’s hand away, fled briefly, was captured after ~20 feet and a scuffle, and a .40 caliber handgun was found in his right back pocket.
Trial court found the 911 caller was an eyewitness, the tip and officers’ observations provided reasonable suspicion and authority to frisk; suppression denied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the anonymous tip + officers’ observations provided reasonable, articulable suspicion to stop Bland	Bland: Tip was unreliable and insufficiently corroborated; officers only corroborated appearance and his pocket‑patting, which is not enough for a stop	Commonwealth: 911 eyewitness tip (brandishing gun, pocketed gun) + close temporal/location match and Bland’s pocket‑patting and resistance gave reasonable suspicion and supported frisk	Court: Held tip and officer observations, under totality (Navarette framework), furnished reasonable suspicion to stop and frisk; suppression properly denied
Whether frisk/search of Bland’s person was justified by officer safety concerns (Terry frisk)	Bland: No basis to believe he was armed beyond matching description and pocket‑patting	Commonwealth: Eyewitness report of brandishing and placing gun in pocket, timely/location match, and Bland’s actions justified a weapons frisk	Court: Held a reasonably prudent officer could believe safety was at risk and frisk was authorized

Navarette v. California, 572 U.S. 393 (2014) (911 eyewitness tip + temporal/location corroboration can supply reasonable suspicion)
Florida v. J.L., 529 U.S. 266 (2000) (anonymous tip lacking basis of knowledge and corroboration insufficient for frisk)
Alabama v. White, 496 U.S. 325 (1990) (anonymously supplied predictive information can lend reliability to a tip)
Terry v. Ohio, 392 U.S. 1 (1968) (officer may conduct brief investigatory stop and frisk based on reasonable, articulable suspicion for officer safety)
Commonwealth v. Smith, 281 Va. 582 (2011) (officer need not be certain suspect is armed; reasonable inferences may justify frisk)