OH1: Apparent authority shown for third party consent to search of def’s bedroom

Consent was granted by someone the police reasonably believed had apparent authority to consent to a search of defendant’s bedroom [no facts given to see how there’s third party consent to a bedroom, so this is immediately suspect]. State v. Burrows, 2017 Ohio App. LEXIS 2696 (1st Dist. June 30, 2017).

“Although there were some factors that weighed against a finding of voluntariness of consent to search the car, other factors weighed in favor of voluntariness, and the court’s choice is well supported by the record.” United States v. Garcia, 2017 U.S. App. LEXIS 11711 (9th Cir. June 30, 2017).*

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