MT makes it clear that PC is not required for a request for consent search of an automobile. “A knowing and voluntary consent, in and of itself, is sufficient to justify a warrantless search of an automobile. Therefore, we reverse that portion of Shaw which requires a finding of probable cause in conjunction with the consent exception to the search warrant requirement.” State v. Copelton, 2006 MT 182, 140 P.3d 1074 (August 8, 2006).

911 call brought officer to house, and he knocked on the door and a woman answered in her underwear with a welt under her eye, and she said she was scared. He came in without asking based on an apparent assault that just occurred. “We need not address whether Donna consented to Officer Harmuth’s entry into the house because the entry was justified under the emergency doctrine.” White v. State, 201 S.W.3d 233 (Tex. App. – Ft. Worth August 10, 2006).

It is settled in Texas that even passengers have standing to challenge a stop of the vehicle they were in, even if they lack standing to challenge its search. Castro v. State, 202 S.W.3d 348 (Tex. App. – Ft. Worth August 10, 2006).

Utah reaches potentially waived search issue to avoid unnecessary post-conviction claim. State v. Dunkel, 2006 UT App 339, 143 P.3d 290 (August 10, 2006).*

“Key to the case before us is the proposition that follows from the one just discussed: Ambiguous actions or statements do not operate to effectively withdraw an individual’s prior valid consent to a search or act to place limits on the scope of an ongoing consensual search.” Id. (distinguishing cases with explicit withdrawal).