Michael Allen Kirkpatrick v. Commonwealth of Virginia

Summary

The court affirmed Kirkpatrick's robbery conviction, holding that evidence concerning the theft of the shotgun and related events was admissible because it was materially connected to the charged robbery and completed the circumstantial chain linking Kirkpatrick to it. The court also upheld the warrantless seizure of the shotgun and shells as a reasonable search incident to a lawful arrest under the law applicable when the search occurred. Although the court recognized the intervening change in search-incident-to-arrest doctrine, it held that the newer rule applied only prospectively.