Harris v. Commonwealth
In Harris v. Commonwealth, 241 Va. 146, 400 S.E.2d 191 (1991), a police officer stopped a vehicle for an equipment violation after an informant had reported the vehicle would contain drugs. Id. at 148, 400 S.E.2d at 192.
During a frisk of the passenger for weapons, the officer detected a film container, which he removed and searched. Id.
The Supreme Court specifically noted that the officer "knew from his personal experience of working 'plain clothes assignments' and 'making arrests' that certain people kept their narcotics and drugs in film canisters." Id. at 154, 400 S.E.2d at 196.
Nonetheless, the Court rejected the Commonwealth's argument that the seizure of the canister and the search of it were lawful.