Helms v. Commonwealth

Opinion

BAKER, J.

Norman Jeffrey Helms (appellant) appeals his bench trial conviction by the Circuit Court of Prince William County (trial court) for possession of phencyclidine (PCP). He asserts that the trial court erred by failing to suppress (1) the evidence of PCP discovered in a film canister found in his possession during a lawful pat-down search of his person, and (2) the laboratory analysis of the residue found in a pipe taken from him during the course of the pat-down.

A confidential informant told the Prince William County police that PCP was being sold from the premises known as 8633…