Commonwealth v. Parks

The Defendant’s Motion to Suppress must be denied. To investigate by questioning, an officer need only a reasonable suspicion that a crime is being committed. See, Section 19.2-83, Code of Virginia. The officer had such reasonable suspicion in this case. The surreptitious actions of the Defendant in concealing the item she had by swallowing it furnished probable cause to arrest her. Therefore, the subsequent search of the Defendant was pursuant to a lawful arrest.