Defendant’s search challenge was to a protective sweep, but not to the probable cause for the search warrant. That was a waiver of the probable cause issue. Commonwealth v. Smith, 2018 Va. App. LEXIS 115 (May 1, 2018); Commonwealth v. Cockrill, 2018 Va. App. LEXIS 114 (May 1, 2018).
The stop was based on traffic offenses, not four surveillance warrants as defendant contends. The stop was not unreasonably prolonged under Rodriguez. United States v. Lawson, 2018 U.S. App. LEXIS 11386 (9th Cir. May 2, 2018).*