Waller v. Commonwealth

ANNUNZIATA, Judge.

Willie Randy Waller (appellant) was convicted of distributing cocaine in violation of Code § 18.2-248. On appeal, appellant contends the trial court erred in admitting a certificate of analysis of the cocaine in violation of the statutory requirements. Finding no error, we affirm his conviction.

On October 30, 1996, Officer Lloyd Holland observed the driver of a car, later identified as Larry Lewis (buyer), give money to appellant in exchange for a small object. Holland testified that from his vantage point, he “couldn’t say .that for sure that it was a rock of crack cocaine,…