CA6: Parents had apparent authority to consent to search of common computer in the house

Officers came to defendant’s house for a knock-and-talk about child pornography traced back to his IP address. He wasn’t home but his parents were. Because the computers were used by all, sitting in the dining room, and his parents paid the internet bill, his parents had apparent authority to consent to a search of the computers. The fact he had an individual profile was not enough to create a reasonable expectation of privacy because it was not password protected. United States v. Trejo, 471 Fed. Appx. 442 (6th Cir. 2012).

Officers found a marijuana patch outside defendant’s curtilage and followed footprints in the mud to defendant’s house. Officers came close to the curtilage, in making their observations, and they actually entered an outbuilding within the curtilage arguing protective sweep because of fresh footprints. That incursion, however, never was revealed to the issuing magistrate, so it was valid under inevitable discovery. United States v. Witherspoon, 467 Fed. Appx. 486 (6th Cir. 2012).*