The officer saw defendant recklessly driving, but wasn’t able to stop him. Staleness for arrest for that did not dissipate within three hours before he saw defendant again. Hairston v. Commonwealth, 2017 Va. App. LEXIS 99 (April 11, 2017) (see Treatise § 6.02 n.22).
Defendant’s admission he used methamphetamine was reasonable suspicion for a probation search. Defendant also consented to the search. United States v. Wolff, 2015 U.S. Dist. LEXIS 187805 (D.N.D. March 18, 2015).*