Williams v. Commonwealth
In Williams v. Commonwealth, 4 Va. App. 53, 67, 354 S.E.2d 79, 87 (1987), the Court held that "suspicion of narcotics possession and distribution . . . gives rise to an inference of dangerousness." Id.
The officers in Williams had no information that Williams was violent or armed.
The protective pat-down search was upheld because it was reasonable "in light of the fact that the officers had a reasonable suspicion that Williams was presently engaged in narcotics distribution." Id.