Joseph Leon Farmer, Jr. v. Commonwealth of Virginia

Court of Appeals of Virginia·Decided July 21, 2026·No. 1834253·Unpublished

Opinion

COURT OF APPEALS OF VIRGINIA

Record No. 1834-25-3

JOSEPH LEON FARMER, JR. v. COMMONWEALTH OF VIRGINIA

Present: Chief Judge Decker, Judges Raphael and White Argued at Lexington, Virginia Opinion Issued July 21, 2026*

FROM THE CIRCUIT COURT OF THE CITY OF LYNCHBURG J. Frederick Watson, Judge

Matthew L. Pack (M. Pack Law, PLLC, on brief), for appellant.

Sheri H. Kelly, Assistant Attorney General (Jason S. Miyares,1 Attorney General, on brief), for appellee.

MEMORANDUM OPINION BY JUDGE KIMBERLEY SLAYTON WHITE

Joseph Leon Farmer, Jr. was pulled over for speeding. After a K-9 scan around his

vehicle, the canine alerted officers to the presence of controlled substances. Upon subsequent

search of the vehicle, officers found pills and a firearm. Farmer was eventually charged and

convicted of possession of fentanyl; possession with intent to distribute oxycodone; possession

of a firearm while possessing with intent to distribute a Schedule I/II controlled substance;

possession of a firearm on or about his person while possessing with intent to distribute a

Schedule I/II controlled substance; driving without a license; carrying a concealed weapon;

* 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. purchasing a firearm without a background check; and possessing a firearm after having been

convicted of a non-violent felony. He timely appealed these convictions.

In this appeal, he makes five assignments of error that we organize into three sections.

First, assignments of error one through three challenge the sufficiency of the evidence for

possession of oxycodone, fentanyl, and a firearm. Second, assignment of error four asserts abuse

of discretion for admission of evidence gained from what Farmer characterizes as a “prolonged”

traffic stop. Finally, assignment of error five challenges the use of a predicate non-violent felony

conviction as the basis of a felon in possession of a firearm conviction. As we discuss below,

Rule 5A:20 and the approbate and reprobate doctrine prevent us from addressing a number of his

assignments of error. As to the rest, we find no error and affirm.

BACKGROUND

“In accordance with familiar principles of appellate review, the facts will be stated in the

light most favorable to the Commonwealth, the prevailing party at trial.” Meade v. Commonwealth,

74 Va. App. 796, 802 (2022) (quoting Gerald v. Commonwealth, 295 Va. 469, 472 (2018)).

“Accordingly, we regard as true all credible evidence favorable to the Commonwealth and all

inferences that may reasonably be drawn from that evidence.” Id. (quoting Gerald, 295 Va. at 473).

I. Traffic Stop

On May 21, 2022, Detective Joshua Massie noticed Farmer driving down a residential

street at what appeared to be a faster speed than the 25 mile per hour speed limit. Massie

followed and paced Farmer’s vehicle and determined he was traveling at approximately 46 miles

per hour. Massie initiated a traffic stop, and after Farmer pulled into a parking lot, Massie

approached the vehicle and spoke to Farmer. When asked for identification, Farmer lifted a

brown Louis Vuitton bag, set it back down, and stated that he had no identification with him. He

-2- did, however, give Massie the vehicle’s registration and his date of birth. Farmer denied having

drugs or guns in the vehicle.

Massie contacted dispatch to determine if Farmer had a revoked or suspended license and

to check for active arrest warrants. Massie confirmed with dispatch that Farmer did not have a

license and then used his in-car computer to find information about Farmer and his vehicle. He

also used his department issued cell phone to access the traffic court schedule to find a return

court date for the summons.

While Massie began typing the speeding offense summons, another officer told Farmer to

exit the vehicle so that a K-9 scan could be performed by Officer Javaz Williams and his canine

partner, Kairos, around the exterior of the vehicle. The scan resulted in a positive alert.

Upon this alert, Massie stopped writing the summons and began conducting a search of

the vehicle, believing he had probable cause to support the search. Inside the Louis Vuitton bag,

he found an acetaminophen bottle containing 41 blue pills, an amber bottle containing 52 white

pills, a white bottle containing 10 gray pills, and two debit cards, one in Farmer’s name and one

in the name of Aniyah Carraway. At the prompting of Officer Harris, who was searching the

passenger side of the vehicle, Massie also found a Glock 17 Gen5 nine-millimeter pistol with

bullets in the magazine on the driver’s side floor near the emergency brake. Massie found an

iPhone on the driver’s side floor as well. Finally, he found a flip phone and $2,808 of cash in

hundreds, fifties, twenties, and tens in Farmer’s pocket.

After the search, Massie arrested Farmer and informed him of his Miranda2 rights. After

taking Farmer to the Lynchburg Police Station, Massie interviewed him further. Farmer initially

said he was not working, but when pressed by Massie about the “banded up” cash, Farmer said

that he sells clothes on Instagram through his limited liability company. Massie later determined

2 Miranda v. Arizona, 384 U.S. 436 (1966). -3- that no such LLC exists and told Farmer that he would seek a search warrant for the contents of

Farmer’s phone to see the Instagram account. Massie also asked Farmer about the gun in the

vehicle, and Farmer said, “[t]hat’s just for protection” and stated he bought it without a

background check from a person whose name he could not recall. When asked about the “oxys,”

Farmer said, “I take pills.” Massie asked, “you had ten milligrams, twenty milligrams, and thirty

milligrams that you just take on your own?” Farmer responded, “Yeah, I take ‘em all day.”

When asked who prescribed the pills, Farmer ended the interview, saying “we can have this in

court.”

While in jail, Farmer made five phone calls to Aniyah Carraway, the mother of his child.

Massie listened to the calls. During these calls, Farmer mentioned pills in separate jars and the

gun in his vehicle. He told Carraway to delete his Facebook and Instagram accounts, erase his

Apple iCloud account, remove any association between that account and his phone numbers, and

delete saved videos in his Snapchat account. He later asked her to confirm that she had

completed these tasks. He also asked her to contact the cell phone companies and get new

numbers assigned to his cell phones. Further, he “indicated that he had too many clothes down

at some location,” specifically blue and white hoodies, and “ask[ed] if Carraway could take his

clothes to her dad’s.” According to Massie, he asked her, “[D]o you understand what I’m talking

about, like do you get what I’m saying[?]”

II. Evidence

Detective Massie sent the pills collected from the vehicle to the Virginia Department of

Forensic Science (DFS) for analysis. A DFS forensic scientist tested one pill from each

container taken from the Louis Vuitton bag—a blue pill from the acetaminophen bottle was

found to contain fentanyl, a white pill from an amber bottle was found to contain oxycodone and

acetaminophen, and a gray pill from a white bottle was found to contain oxycodone.

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Joseph Leon Farmer, Jr. v. Commonwealth of Virginia, (Va. Ct. App. 2026).

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