Beverly v. Commonwealth
In Beverly v. Commonwealth, 12 Va. App. 160, 403 S.E.2d 175 (1991), the Court held that the bag of cocaine found in a heavily-traveled roadway was correctly held to be in the defendant's possession.
Earlier, the defendant tried to flee from approaching officers and dropped an unidentified object in the roadway. See id. at 165, 403 S.E.2d at 177-78.
"We hold that the evidence was sufficient to permit an inference that the drugs found on the roadway were discarded by appellant as he sped from his arrest, and was sufficient to exclude any reasonable hypothesis of innocence which flowed from the evidence." Id. at 165, 403 S.E.2d at 178