Jefferson v. Commonwealth

In Jefferson v. Commonwealth, 27 Va. App. 1, 497 S.E.2d 474 (1998), the Court held that overlapping tips from two separate reliable informants, based on their firsthand knowledge and coupled with police corroboration of Jefferson's description and location, provided probable cause to arrest him. See Jefferson, 27 Va. App. at 13-14, 497 S.E.2d at 480. In Jefferson, Officer Hoyt became acquainted with the two informants when they were arrested on previous occasions. See id. at 7, 497 S.E.2d at 477. Both provided Hoyt with information about Jefferson in the hope of obtaining leniency on pending charges. See id. Hoyt had worked with the second informant "maybe a dozen times" over three or four months during which time he had provided information which had led to several arrests but which had not yet resulted in any convictions. See Jefferson, 27 Va. App. at 7-8, 497 S.E.2d at 477. In Jefferson, two different informants observed Jefferson sell drugs.In Jefferson, the officers did not arrive at the scene until over three hours after receiving the tip. See 27 Va. App. at 7-8, 497 S.E.2d at 477. Upon their arrival, they found Jefferson exiting the rear of the house at 101 North Virginia Avenue rather than on the nearby street corner where he had been seen by the informants, see id., and no evidence established whether he was in the company of the two individuals with whom he had previously been seen. None of the officers knew Jefferson personally, and they identified him by description only. See id. Code 18.2-308.2, at the time of the offense, provided that it was unlawful for a previously convicted felon to "knowingly and intentionally possess or transport any firearm." The statute does not contain a definition of "firearm."