of backpack found on premises pursuant to search warrant for “formulas for making methamphetamine”); cf. Graham, 638 F.2d at 1114 (noting “defendant is mistaken in his contention that the rationale used to define the scope of a search incident to an arrest is equally applicable in defining the scope of a search of the person authorized by a warrant”). Virginia law expressly provides that, in the absence of a search warrant or probable cause coupled with exigent circumstances, see, e.g., Jefferson v. Commonwealth, 27 Va.App. 1, 16, 497 S.E.2d 474, 481 (1998), the Commonwealth bears the burden of proving a suspect has consented to the search conducted, and a court evaluating whether the search exceeded the scope of the consent must determine what “the typical reaso (10th Cir.1986) (<HOLDING>). In appellant’s case, by contrast, the bag
holding that the defendant voluntarily consented to a search and the patdown of his person did not exceed the scope of his consent which included a search of the groin area holding that search of backpack constituted a search of defendants person and was not authorized by search warrant for premises holding that where defendant consented to search of his car and stood by as agent conducted a thorough and systematic search which included removal of vehicles back seat and raising of cars rear quarter panel defendants failure to object to search indicated search was within scope of consent holding that acquiescence to a strip and body cavity search did not extend the scope of defendants consent to search his person because of the highly intrusive nature of the search holding that where defendant consented to search of the glove box the trunk and the remainder of his vehicle and stood by without objecting when trooper searched beneath back seat of vehicle it was reasonable to conclude that defendants acquiescence indicated that the search was within the scope of the consent