James Levi McDonald v. Commonwealth of Virginia

CourtCourt of Appeals of Virginia
DecidedFebruary 3, 2026
Docket0941244
StatusUnpublished

This text of James Levi McDonald v. Commonwealth of Virginia (James Levi McDonald v. Commonwealth of Virginia) 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
James Levi McDonald v. Commonwealth of Virginia, (Va. Ct. App. 2026).

Opinion

COURT OF APPEALS OF VIRGINIA

Present: Judges Malveaux, White and Senior Judge Annunziata UNPUBLISHED

JAMES LEVI MCDONALD MEMORANDUM OPINION* BY v. Record No. 0941-24-4 JUDGE KIMBERLEY SLAYTON WHITE FEBRUARY 3, 2026 COMMONWEALTH OF VIRGINIA

FROM THE CIRCUIT COURT OF ARLINGTON COUNTY Daniel T. Lopez, Judge

(Peter M. Baskin; Peter M. Baskin, P.C., on brief), for appellant.

(Jason S. Miyares,1 Attorney General; Anna M. Hughes, Assistant Attorney General, on brief), for appellee.

Appellant James McDonald was charged and convicted of possession with intent to

distribute three controlled substances (LSD, marijuana, and psilocyn), and possession of a

firearm while in possession of controlled substances. He makes eight assignments of error that

we group into five categories. (A) The trial court erred by admitting evidence discovered from a

warrant that lacked probable cause (assignment of error 1). (B) The trial court erred in finding

actual or constructive and contemporaneous possession of controlled substances and a firearm

based on the evidence (assignments of error 2 and 8). (C) The trial court erred in allowing

testimony and evidence about prior crimes not charged against McDonald (assignment of error

3). (D) The trial court erred in granting the Commonwealth’s instructions (10, 11, 12, 14, 15,

and 16) that did not include the date of alleged possession, in failing to instruct the jury that

possession must be contemporaneous with knowledge and intent, and in failing to instruct the

* This opinion is not designated for publication. See Code § 17.1-413(A). 1 Jay C. Jones succeeded Jason S. Miyares as Attorney General on January 17, 2026. jury on proximity, dominion, and control in establishing constructive possession (assignments of

error 4, 5, and 6).2 Finally, (E) the trial court erred in preventing McDonald from complying

with the contemporaneous objection rule during closing argument (assignment of error 7).

Following a description of the facts relating to these assignments of error, we address the

merits of McDonald’s arguments. We affirm the trial court’s judgment.3

I. BACKGROUND

On August 16, 2022, a postal inspector observed a damaged priority mail package to be

delivered that same day from Long Beach, California, addressed to “James M” at the address

where McDonald resided in Arlington, Virginia (the “Arlington Address”). Visible through the

packaging was what appeared to the inspector to be controlled substances—suspected psilocybin

mushrooms of about 9.5 ounces and suspected marijuana edibles. The inspector turned the

package over to the Arlington County Police, not to be delivered to the intended address. Police

were able to determine that McDonald was “associated with” the Arlington Address. The postal

inspector subsequently discovered and notified law enforcement about a second package from

Long Beach to be delivered to “James M” at the Arlington Address on August 19. An Arlington

officer observed McDonald pick up the package from the front porch of the Arlington Address

and bring it into the house on the date appointed for delivery. Finally, the postal inspector

discovered a third package due for delivery on August 22 to be delivered to “James M” at the

Arlington Address.

2 For this third part, McDonald mentions his own proffered Instructions B, C, D, and H. However, he develops the issue only with regard to Instruction C and so waives any assignment of error with respect to the others for failure to develop the issue on brief. 3 Having examined the briefs and record in this case, the panel unanimously agrees that oral argument is unnecessary because “the facts and legal arguments are adequately presented in the briefs and record, and the decisional process would not be significantly aided by oral argument.” See Code § 17.1-403(ii)(c); Rule 5A:27(c). -2- On August 22, 2022 police obtained a search warrant for the house at the Arlington

Address. The warrant authorized the search for evidence of possession of and intent to distribute

controlled substances in violation of Code § 18.2-248 and Code § 18.2-248.01. The affidavit

submitted in support of the search warrant highlighted the officer’s “extensive training in drug

identification, drug distribution methods, and drug enforcement techniques . . . .” It also

contained eight lengthy statements about what drug traffickers and drug users “commonly” do in

the course of their illegal activities related to concealment of evidence, maintenance of

transactional information, communications, record-keeping, possession of paraphernalia, etc.

The warrant authorized a search for “evidence of the crime of Possession with Intent to

Distribute of a controlled substance . . . .” Items appearing in a non-exhaustive list included

“documents, USPS mail packages, . . . scales, packaging materials, phone records, . . . firearms,

. . . computers, cellular phones, business records.” Facts specific to McDonald himself included

his connection to the packages, his connection to the Arlington Address, and McDonald’s

previous arrests for drug possession.

On August 22, officers executed the search warrant on the Arlington Address. One

officer testified that while executing the warrant, he observed a “red object caught out of the

corner of my eye to the rear of the residence” (also a “flash of red”) near the back deck.4 After

approaching the rear of the house, that officer saw McDonald in the back yard moving toward

him from a direction he believed would be “behind” a shed, though he testified that he did not

see him behind the shed. After arresting McDonald, the officer found a red backpack with the

word “Cookies” on it in the corner of the yard between the shed wall and a fence (the place

behind the shed from where he believed McDonald had emerged). The backpack contained

controlled substances, including two bags of marijuana, a bag of psilocybin mushrooms, and a

4 The “flash of red” can be seen in stills of Luzier’s body cam as well as the video itself. -3- bag of LSD tabs. When asked whether he could say for sure that the red flash was the red

backpack he found near the shed, the officer responded, “For 100 percent, no I cannot.” Another

officer, also at the residence executing the warrant, testified that there was nothing in the bag

with McDonald’s name on it.

Police then searched the residence at the Arlington Address. They searched an upstairs

room that had its own key access, a bed, a sitting area, a kitchenette, and a bathroom. The

room’s interior door, which officers believed “originally led to the rest of the house,” was

“sealed off” with “tape around the seams” and “fabric or cardboard” covering it. It was also

locked and had a desk in front of it, leaving the doors to the back and front decks as the only

access points to the room. Additionally, only the back deck had a stairway leading up to the

door.

Inside the upstairs room at the Arlington Address, they found THC cartridges, marijuana

residue and stems, a firearm, ammunition, electronics, postal boxes, and items with McDonald’s

name on it. Some items were mailings to the Arlington Address with McDonald as the recipient;

bank statements, envelopes, and cards with his name on them; a handwritten card in an ID

window of a wallet with his name and the Arlington Address listed; drug paraphernalia; a

backpack with a “cookies” logo similar to the one found by the shed; and a firearm with an

extended magazine.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Illinois v. Gates
462 U.S. 213 (Supreme Court, 1983)
Sullivan v. Com.
701 S.E.2d 61 (Supreme Court of Virginia, 2010)
Cordon v. Com.
701 S.E.2d 803 (Supreme Court of Virginia, 2010)
Thomas v. Com.
688 S.E.2d 220 (Supreme Court of Virginia, 2010)
Malbrough v. Com.
655 S.E.2d 1 (Supreme Court of Virginia, 2008)
Dowden v. Commonwealth
536 S.E.2d 437 (Supreme Court of Virginia, 2000)
Anthony Michael Sfreddo v. Vanessa Sfreddo
720 S.E.2d 145 (Court of Appeals of Virginia, 2012)
Reid v. Commonwealth
698 S.E.2d 269 (Court of Appeals of Virginia, 2010)
Jones v. Commonwealth
660 S.E.2d 343 (Court of Appeals of Virginia, 2008)
Cunningham v. Commonwealth
643 S.E.2d 514 (Court of Appeals of Virginia, 2007)
Kenneth Ray Lowe v. Commonwealth of Virginia
548 S.E.2d 904 (Court of Appeals of Virginia, 2001)
Newton v. Commonwealth
512 S.E.2d 846 (Court of Appeals of Virginia, 1999)
Pavlick v. Commonwealth
497 S.E.2d 920 (Court of Appeals of Virginia, 1998)
Williams v. Commonwealth
354 S.E.2d 79 (Court of Appeals of Virginia, 1987)
Spencer v. Commonwealth
393 S.E.2d 609 (Supreme Court of Virginia, 1990)
Scott v. Commonwealth
323 S.E.2d 572 (Supreme Court of Virginia, 1984)
Garland v. Commonwealth
300 S.E.2d 783 (Supreme Court of Virginia, 1983)
State Highway Commissioner v. Easley
207 S.E.2d 870 (Supreme Court of Virginia, 1974)
Thomas v. Commonwealth
607 S.E.2d 738 (Court of Appeals of Virginia, 2005)
People v. Trimble
537 N.E.2d 363 (Appellate Court of Illinois, 1989)

Cite This Page — Counsel Stack

Bluebook (online)
James Levi McDonald v. Commonwealth of Virginia, Counsel Stack Legal Research, https://law.counselstack.com/opinion/james-levi-mcdonald-v-commonwealth-of-virginia-vactapp-2026.