Crews v. Commonwealth

Opinion

BRAY, J.

Wayne Phillip Crews (defendant) was convicted in a bench trial for distributing cocaine in violation of Code § 18.2-248. On appeal, he argues (1) that the certificate of analysis did not sufficiently establish the chain of custody of the contraband, and (2) that the court erred in admitting into evidence an audio tape recorded at the time of the offense. We disagree and affirm the conviction.

Under familiar principles of appellate review, we examine the evidence in the light most favorable to the Commonwealth, granting to it all reasonable inferences fairly deducible therefrom.…