Patterson v. Commonwealth
In Patterson v. Commonwealth, 19 Va. App. 698, 702, 454 S.E.2d 367, 369-70 (1995), the Court held that possession of a controlled substance is a lesser-included offense of manufacture of a controlled substance. The Court concluded that, in order to plant, cultivate, grow, or harvest marijuana, one must necessarily possess the marijuana.
All of the elements of possession of a controlled substance are included within the elements of manufacturing a controlled substance.