Commonwealth of Virginia v. Lashant Leonardo White

Summary

After the Court of Appeals vacated White's conviction for possession of heroin with intent to distribute (third or subsequent offense) — holding that the trial court erred in denying his motion to suppress and that the error was not harmless — the Supreme Court of Virginia reversed. Applying the constitutional harmless-error standard, the Court concluded that any error connected to the trial court's consideration of evidence seized from a plastic bag in the girlfriend's motel room was harmless beyond a reasonable doubt, because the prosecution rested overwhelmingly on unchallenged evidence found on White's person indicating drug distribution. Invoking judicial restraint, the Court chose the best and narrowest ground, expressly declined to resolve the underlying Fourth Amendment apparent-authority question raised by the consent search, vacated as moot the suppression portion of the Court of Appeals' opinion, and reinstated the conviction.