Brown v. Commonwealth

Opinion

BRAY, J.

Eduardo Martinez Brown (defendant) was convicted of possession of cocaine with intent to distribute and sentenced, in accordance with the jury’s verdict, to forty years imprisonment. He appeals, contending that the trial court erred in admitting testimony that associated the location of the offense with notorious criminal activity. We disagree and affirm.

The evidence disclosed that Officers Angelo Chiota (Chiota) and Kenneth Hatten (Hatten), “responding ... to [a] complaint of open drug sales,” observed defendant exit a cab and enter a “park” located in Alexandria, Virginia. It…