If you’re going to contest consent, you better have some testimony countering the officers

While the state carries the burden on warrantless searches, if the officer’s testimony is uncontested, it can certainly be credited by the trial court, and that clearly will be sufficient for appellate review: “Here, the defendant was under arrest at the time he executed a consent to search. Nonetheless, the defendant signed a consent-to-search form and, by Deputy Ashford’s account, fully cooperated with the investigation. Defendant did not dispute any of this testimony. Consequently, the State sufficiently proved that the defendant freely and voluntarily consented to a search of his person and property.” State v. Williams, 2015 La. App. LEXIS 2657 (La.App. 1 Cir. Dec. 23, 2015).