“It is common authority, not legal ownership, that confers actual authority to consent to a search. … In this case, the evidence was sufficient for the court to find that A shared common authority with defendant over the bedroom and the bed. Specifically, there was evidence that A had been living in the house for six years, had been sharing the bedroom and the bed with defendant for six years, kept her clothes in the bedroom closet, and had personal items all over the bedroom. There was no evidence that A’s authority over the bedroom or the bed was limited.” State v. Carrillo, 304 Ore. App. 192, 2020 Ore. App. LEXIS 623 (May 13, 2020).
Franks doesn’t apply to searches incident to arrest. United States v. Sportsman, 2020 U.S. Dist. LEXIS 84918 (D. Kan. May 14, 2020).*