E.D.Tenn.: Householder had no apparent authority to consent to a search of a metal box she identified as somebody else’s

Householder’s consent did not apply to a search of a metal box the householder said belonged to someone else. “While it is undisputed that the officers had authority to search Cuff’s residence based on her consent, the Court finds that Cuff did not have actual or apparent authority to consent to the officers’ search of the unopened metal box because Cuff specifically told officers the box belonged to Defendant.” United States v. Gibson, 2017 U.S. Dist. LEXIS 83632 (E.D. Tenn. June 1, 2017).