Timothy Craighead v. Commonwealth of Virginia

CourtCourt of Appeals of Virginia
DecidedNovember 28, 2000
Docket0204003
StatusUnpublished

This text of Timothy Craighead v. Commonwealth of Virginia (Timothy Craighead 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
Timothy Craighead v. Commonwealth of Virginia, (Va. Ct. App. 2000).

Opinion

COURT OF APPEALS OF VIRGINIA

Present: Judges Elder, Frank and Humphreys Argued at Salem, Virginia

TIMOTHY CRAIGHEAD MEMORANDUM OPINION * BY v. Record No. 0204-00-3 JUDGE LARRY G. ELDER NOVEMBER 28, 2000 COMMONWEALTH OF VIRGINIA

FROM THE CIRCUIT COURT OF FRANKLIN COUNTY William N. Alexander, II, Judge

Carolyn H. Furrow for appellant.

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

Timothy Craighead (appellant) appeals from his bench trial

conviction for possession of cocaine with intent to distribute

in violation of Code § 18.2-248. On appeal, he contends the

court erroneously denied his motion to suppress the evidence as

the product of an unreasonable search. We hold the reliable

informant's tip, coupled with police corroboration and

independent knowledge of related facts, provided probable cause

for appellant's warrantless arrest and the search incident

thereto. Therefore, we affirm appellant's conviction.

At a hearing on a defendant's motion to suppress, the

Commonwealth has the burden of proving the challenged action did

* Pursuant to Code § 17.1-413, this opinion is not designated for publication. not violate the defendant's constitutional rights. See Simmons

v. Commonwealth, 238 Va. 200, 204, 380 S.E.2d 656, 659 (1989).

On appeal, we view the evidence in the light most favorable to

the prevailing party, here the Commonwealth, granting to it all

reasonable inferences fairly deducible therefrom. See

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

47, 48 (1991). "[W]e are bound by the trial court's findings of

historical fact unless 'plainly wrong' or without evidence to

support them," McGee v. Commonwealth, 25 Va. App. 193, 198, 487

S.E.2d 259, 261 (1997) (en banc), but we review de novo the

trial court's application of defined legal standards such as

probable cause to the particular facts of the case, Ornelas v.

United States, 517 U.S. 690, 699, 116 S. Ct. 1657, 1663, 134

L. Ed. 2d 911 (1996).

"[T]he test of constitutional validity [of a warrantless

arrest] is whether at the moment of arrest the arresting officer

had knowledge of sufficient facts and circumstances to warrant a

reasonable man in believing that an offense has been committed."

Bryson v. Commonwealth, 211 Va. 85, 86-87, 175 S.E.2d 248, 250

(1970). "Probable cause to arrest must exist exclusive of the

incident search. So long as probable cause to arrest exists at

the time of the search, however, it is unimportant that the

search preceded the formal arrest if the arrest '"followed

quickly on the heels of the challenged search."'" Carter v.

Commonwealth, 9 Va. App. 310, 312, 387 S.E.2d 505, 506 (1990)

- 2 - (citation omitted). "Probable cause exists where 'the facts and

circumstances within [the arresting officers'] knowledge and of

which they had reasonably trustworthy information [are]

sufficient in themselves to warrant a man of reasonable caution

in the belief that' an offense has been or is being committed."

Brinegar v. United States, 338 U.S. 160, 175-76, 69 S. Ct. 1302,

1310-11, 93 L. Ed. 1879 (1949) (citation omitted). Courts must

view and weigh the evidence supporting probable cause "'as

understood by those versed in the field of law enforcement.'"

Illinois v. Gates, 462 U.S. 213, 231-32, 103 S. Ct. 2317,

2328-29, 76 L. Ed. 2d 527 (1983) (quoting United States v.

Cortez, 449 U.S. 411, 418, 101 S. Ct. 690, 695, 66 L. Ed. 2d 621

(1981)).

When the factual basis for probable cause is provided by an

informant, the informant's (1) veracity, (2) reliability, and

(3) basis of knowledge are "highly relevant" factors in the

overall totality-of-the-circumstances probable cause analysis.

See id. at 230, 233, 103 S. Ct. at 2328, 2329.

[A] deficiency in [either veracity or basis of knowledge] may be compensated for, in determining the overall reliability of a tip, by a strong showing as to the other, or by some other indicia of reliability. If, for example, a particular informant is known for the unusual reliability of his predictions of certain types of criminal activities in a locality, his failure in a particular case, to thoroughly set forth the basis of his knowledge surely should not serve as an absolute bar to a finding of probable cause based on his tip.

- 3 - Id. at 233, 103 S. Ct. at 2329-30 (citations omitted). "When an

officer receives from a known reliable informant a report that a

felony is being committed that is so detailed as to raise an

inference either of personal observation or of acquisition of

the information in a reliable way then the officer has probable

cause to arrest." McKoy v. Commonwealth, 212 Va. 224, 227, 183

S.E.2d 153, 156 (1971).

We applied these principles in Jefferson v. Commonwealth,

27 Va. App. 1, 497 S.E.2d 474 (1998), in which we held that

overlapping tips from two separate reliable informants, based on

their firsthand knowledge and coupled with police corroboration

of Jefferson's description and location, provided probable cause

to arrest him. See id. at 13-14, 497 S.E.2d at 480. In

Jefferson, Officer Hoyt became acquainted with the two

informants when they were arrested on previous occasions. See

id. at 7, 497 S.E.2d at 477. Both provided Hoyt with

information about Jefferson in the hope of obtaining leniency on

pending charges. See id. Hoyt had worked with the second

informant "maybe a dozen times" over three or four months during

which time he had provided information which had led to several

arrests but which had not yet resulted in any convictions. See

id. at 7-8, 497 S.E.2d at 477.

Although the facts in Jefferson are not identical to those

in appellant's case, we hold they are sufficiently analogous to

- 4 - support the trial court's denial of appellant's motion to

suppress. In Jefferson, two different informants observed

Jefferson sell drugs, whereas in appellant's case, only one

informant furnished Officer Hubbard with information about

appellant's drug transactions and did not specifically state

that he observed the transactions take place. However, the

overall degree of reliability of the informant in appellant's

case was higher than that of the two informants combined in

Jefferson, and additional facts known to and observed by

Officers Hubbard and Agee strengthened the finding of probable

cause.

In appellant's case, in contrast to Jefferson, no evidence

indicated that the informant gave the information in the hope of

obtaining leniency on an outstanding charge, and the informant

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Related

Brinegar v. United States
338 U.S. 160 (Supreme Court, 1949)
United States v. Cortez
449 U.S. 411 (Supreme Court, 1981)
Illinois v. Gates
462 U.S. 213 (Supreme Court, 1983)
Ornelas v. United States
517 U.S. 690 (Supreme Court, 1996)
United States v. Malchus George Laing
538 F.2d 83 (Fourth Circuit, 1976)
Jefferson v. Commonwealth
497 S.E.2d 474 (Court of Appeals of Virginia, 1998)
McGee v. Commonwealth
487 S.E.2d 259 (Court of Appeals of Virginia, 1997)
Bryson v. Commonwealth
175 S.E.2d 248 (Supreme Court of Virginia, 1970)
Wright v. Commonwealth
278 S.E.2d 849 (Supreme Court of Virginia, 1981)
Simmons v. Commonwealth
380 S.E.2d 656 (Supreme Court of Virginia, 1989)
Carter v. Commonwealth
387 S.E.2d 505 (Court of Appeals of Virginia, 1990)
McKoy v. Commonwealth
183 S.E.2d 153 (Supreme Court of Virginia, 1971)
Commonwealth v. Grimstead
407 S.E.2d 47 (Court of Appeals of Virginia, 1991)

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