Alvarez v. Commonwealth

MOON, Chief Judge.

Jose Alvarez appeals from his conviction of possession of marijuana with intent to distribute in violation of Code § 18.2-248. Alvarez asserts that the trial court erred in: (1) failing to suppress marijuana evidence obtained in a warrantless search that was based upon a narcotics dog “alerting” on a package being transported by bus; and (2) admitting an analysis of the marijuana evidence for which the Commonwealth failed to establish a proper chain of custody.

Holding that: (1) the marijuana evidence was properly obtained under the automobile exception to the warrant…