Hill v. Commonwealth (1989)

In Hill v. Commonwealth, 8 Va. App. 60, 379 S.E.2d 134 (1989) (en banc), neither the cocaine nor an analysis of it was admitted into evidence, but circumstantial evidence was sufficient to prove the nature of the illegal substance transferred. "Users and addicts, if they have gained a familiarity or experience with a drug, may identify it. Numerous courts have permitted lay purchasers of drugs to testify as to the identification of drugs after previous use has been demonstrated." Id. at 63, 379 S.E.2d at 136.