Blow v. Commonwealth

Summary

The Supreme Court of Virginia held that Code § 19.2-56(B), including its requirement that officers provide a copy of the search warrant and affidavit, applies only to search warrants for a place of abode. Because the warrant in this case authorized a search of a commercial clothing store, the court affirmed the Court of Appeals’ judgment upholding the denial of Blow’s suppression motion.

Holdings

1. Code § 19.2-56(B), in its entirety, applies only to search warrants for a place of abode and does not apply to commercial premises.
2. Evidence obtained from the search of Blow's commercial clothing store was not subject to suppression under Code § 19.2-56(B) because the statute does not apply to commercial premises.

Questions Presented

1. Whether Code § 19.2-56(B), including its requirement that officers provide a copy of the search warrant and affidavit, applies to all search warrants or only to search warrants for a place of abode.
2. Whether evidence obtained from the search of the commercial clothing store was subject to suppression because officers did not provide Blow with copies of the search warrant and supporting affidavit.

Disposition

affirmed