Commonwealth of Virginia v. Stanley Ray Parham

CourtCourt of Appeals of Virginia
DecidedSeptember 14, 1999
Docket1066992
StatusUnpublished

This text of Commonwealth of Virginia v. Stanley Ray Parham (Commonwealth of Virginia v. Stanley Ray Parham) is published on Counsel Stack Legal Research, covering Court of Appeals of Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commonwealth of Virginia v. Stanley Ray Parham, (Va. Ct. App. 1999).

Opinion

COURT OF APPEALS OF VIRGINIA

Present: Chief Judge Fitzpatrick, Judges Coleman and Bray Argued by teleconference

COMMONWEALTH OF VIRGINIA MEMORANDUM OPINION * BY v. Record No. 1066-99-2 JUDGE SAM W. COLEMAN III SEPTEMBER 14, 1999 STANLEY RAY PARHAM

FROM THE CIRCUIT COURT OF CHESTERFIELD COUNTY Timothy J. Hauler, Judge

Marla Graff Decker, Assistant Attorney General (Mark L. Earley, Attorney General, on brief), for appellant.

Keith N. Hurley (Cawthorn, Picard & Rowe, on brief), for appellee.

Stanley Ray Parham is charged with possession of cocaine as

the result of officers having found it during a search of Parham's

vehicle. The trial judge ruled that the traffic stop and

resulting search of Parham's vehicle violated his Fourth Amendment

rights and, accordingly, suppressed the evidence. Pursuant to

Code § 19.2-398, the Commonwealth appealed.

Upon review, we find the trial judge's ruling erroneous that

the stop was illegal, and we hold that the search did not violate

the Fourth Amendment. Therefore, we reverse the trial court's

suppression order and remand the case to the circuit court.

* Pursuant to Code § 17.1-413, recodifying Code § 17-116.010, this opinion is not designated for publication. BACKGROUND

At approximately 10:50 p.m., officers involved in a drug

interdiction effort observed Parham's vehicle enter the parking

lot of an apartment complex in a high crime area which, according

to the officers, is known to be associated with the sale and use

of illegal drugs. In accordance with their operating procedure,

when Parham's vehicle remained in the lot only for about two

minutes before exiting, Officer Brown followed the vehicle. After

observing that Parham's vehicle was in violation of Code

§ 46.2-1013 for failure to illuminate the rear license plate,

Brown radioed Officers Gordon and Benson who, in two separate

vehicles, stopped Parham. Brown arrived on the scene shortly

after the stop.

Brown and Gordon had Parham exit his vehicle and step to the

rear of the vehicle in order to observe the equipment violation.

As Parham stood five to ten feet behind the vehicle, Benson's drug

detection dog alerted to Parham. Benson returned the dog to his

police vehicle without walking him around Parham's vehicle. After

the dog alerted to Parham, the officers simultaneously searched

Parham and his vehicle for drugs. Inside the vehicle, the

officers found a crack stem, two small clear bags of cocaine, two

rods used to "stuff [the cocaine] down," and an unidentified red

device. The officers found no drugs on Parham.

- 2 - The trial court suppressed the cocaine seized from Parham's

vehicle after ruling that the traffic violation was a "subterfuge"

whose contrivance did not supply an articulable justification for

stopping the vehicle. In addition, the trial court ruled that

even if the traffic stop was legal, the dog's alert to Parham did

not supply probable cause to search Parham's vehicle.

ANALYSIS

On review of a suppression ruling, we view the evidence in

the light most favorable to the prevailing party and grant to that

party all reasonable inferences fairly deducible therefrom. See

Commonwealth v. Grimstead, 12 Va. App. 1066, 1067, 407 S.E.2d 47,

48 (1991). However, determinations of probable cause and

reasonable suspicion involve mixed questions of fact and law. See

McGee v. Commonwealth, 25 Va. App. 193, 197-98, 487 S.E.2d 259,

261 (1997) (en banc) (citing Ornelas v. United States, 517 U.S.

690, 691 (1996)). Thus, although we are bound by the trial

court's findings of historical fact unless plainly wrong or

without evidence to support them, see id. at 198, 487 S.E.2d at

261, "we review de novo the trial court's application of defined

legal standards to the facts of the case." Giles v. Commonwealth,

28 Va. App. 527, 532, 507 S.E.2d 102, 105 (1998).

We find that, at a minimum, the officers had sufficient

reasonable articulable suspicion to stop Parham's vehicle. See

Ford v. Commonwealth, 28 Va. App. 249, 255, 503 S.E.2d 803, 805-06

- 3 - (1998) (discussing the test to evaluate an investigatory stop).

Officer Brown testified that from fifty feet behind Parham's

vehicle, he could tell that the vehicle's license plate lacked

illumination in violation of Code § 46.2-1013. Before stopping

Parham, Officer Gordon confirmed Brown's observation of the

equipment violation.

Despite an officer's subjective reason for stopping a

vehicle, a stop is legal provided there is an objectively

reasonable basis for the traffic stop. See Whren v. United

States, 517 U.S. 806, 812-13 (1996); Logan v. Commonwealth, 29 Va.

App. 353, 359, 512 S.E.2d 160, 162-63 (1999); Bosworth v.

Commonwealth, 7 Va. App. 567, 570-71, 375 S.E.2d 756, 758 (1989).

Accordingly, regardless of whether the officers had as their

primary purpose stopping the vehicle to allow the dog to sniff for

drugs, the observed traffic violation supplied the officers legal

justification to stop Parham. The officers' ulterior motivation

does not negate the fact that probable cause existed to believe

that Parham was committing a traffic infraction, which gave the

officers legal justification for stopping the vehicle.

Where officers stop a motorist to issue a traffic citation,

the procedure, without more, does not authorize a full search of a

defendant's vehicle. See Knowles v. Iowa, 119 S. Ct. 484, 487-88

(1998). Here, however, the alert from the drug detection dog, in

- 4 - view of the totality of circumstances, supplied sufficient

probable cause to search Parham's vehicle. 1

Among recognized exceptions to the requirement that officers

obtain a warrant to search is the "automobile exception." Where

officers have probable cause to believe that a vehicle contains

evidence of a crime, officers may conduct a search of that vehicle

without first obtaining a warrant. See California v. Acevedo, 500

U.S. 565, 569 (1991).

The test for probable cause does not require "an actual

showing" of criminal activity, but, rather, "only a probability or

substantial chance" of such activity. Illinois v. Gates, 462 U.S.

213, 243-44 n.13 (1983).

In determining whether probable cause to search exists, no hard and fast rule exists which may be rigidly applied to yield a certain result in each case. "Rather, probable cause exists when the facts and circumstances within the officer's knowledge, and of which he has reasonably trustworthy information, alone are sufficient to warrant a person of reasonable caution to believe that an offense has been or is being committed."

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Related

Illinois v. Gates
462 U.S. 213 (Supreme Court, 1983)
California v. Acevedo
500 U.S. 565 (Supreme Court, 1991)
Ornelas v. United States
517 U.S. 690 (Supreme Court, 1996)
Whren v. United States
517 U.S. 806 (Supreme Court, 1996)
Knowles v. Iowa
525 U.S. 113 (Supreme Court, 1998)
Logan v. Commonwealth
512 S.E.2d 160 (Court of Appeals of Virginia, 1999)
Giles v. Commonwealth
507 S.E.2d 102 (Court of Appeals of Virginia, 1998)
Ford v. Commonwealth
503 S.E.2d 803 (Court of Appeals of Virginia, 1998)
McGee v. Commonwealth
487 S.E.2d 259 (Court of Appeals of Virginia, 1997)
Alvarez v. Commonwealth
485 S.E.2d 646 (Court of Appeals of Virginia, 1997)
Bosworth v. Commonwealth
375 S.E.2d 756 (Court of Appeals of Virginia, 1989)
Brown v. Commonwealth
421 S.E.2d 877 (Court of Appeals of Virginia, 1992)
Derr v. Commonwealth
368 S.E.2d 916 (Court of Appeals of Virginia, 1988)
Taylor v. Commonwealth
284 S.E.2d 833 (Supreme Court of Virginia, 1981)
Richards v. Commonwealth
383 S.E.2d 268 (Court of Appeals of Virginia, 1989)
Commonwealth v. Grimstead
407 S.E.2d 47 (Court of Appeals of Virginia, 1991)

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