Moss v. Commonwealth
In Moss v. Commonwealth, 30 Va. App. 219, 225, 516 S.E.2d 246, 249 (1999), the defendant was approached by a police officer in a gas station parking lot.
The officer identified himself and asked for permission to search the defendant and the defendant's car for drugs.
The defendant consented.
While one officer was searching the defendant, another officer observed a marijuana cigarette in the vehicle. The officers also asked for and received consent to search the passenger.
Three officers conducted a strip search of the passenger in the restroom of a nearby gas station and discovered crack cocaine secreted in the passenger's buttocks.
After recovering the narcotics from the passenger, the officers suspected that the defendant might also be concealing narcotics.
They conducted a strip search of the defendant and discovered crack cocaine in the defendant's buttocks. The Court held that the defendant's consent to search his person did not constitute consent to conduct a strip search or a body cavity search. See id. at 225, 516 S.E.2d at 249.