to extend to a particular container, the Fourth Amendment provides no grounds for requiring a more explicit authorization.’ ” Lawrence v. Commonwealth, 17 Va.App. 140, 145, 435 S.E.2d 591, 594 (1993) (quoting Jimeno, 500 U.S. at 252, 111 S.Ct. at 1804). Whether consent to search one’s person includes containers such as a purse or bag held by that person is a matter of first impression in Virginia. We are, however, guided by the reasoning of several of our sister courts considering the import of the term “person” in the context of the search of a person pursuant to a warrant. For example, in United States v. Graham, the Seventh Circuit Court of Appeals concluded that the defendant’s shoulder purse could be considered part of “his person.” See 638 F.2d 1111, 1114 (7th Cir.1981) (<HOLDING>). In holding that such objects are within the
holding that search of defendants purse which he carried was authorized by a warrant to search his person holding that search of shoulder bag was not authorized by search warrant for apartment holding that search of appellants suitcase found on the floor next to the couch on which he was sleeping was an unconstitutional search of his person and was not authorized by a search of the residence holding that search of backpack constituted a search of defendants person and was not authorized by search warrant for premises holding that a shoulder purse carried by a person at the time he is stopped lies within the scope of a warrant authorizing the search of his person