Defendant fled from a car, and a gun was in plain view in the car. The officer acted reasonably in searching the car to secure the firearm under Michigan v. Long [aside from abandonment of the car] because defendant could have circled back to the car and retrieved the gun. Moore v. Commonwealth, 2018 Va. App. LEXIS 147 (June 5, 2018).
Defendant was shown to have consented to the search of his cell phone. United States v. Rodriguez, 2018 U.S. Dist. LEXIS 94320 (W.D. Va. June 5, 2018).*