FL4: Adult son staying with mother did not give her actual or apparent authority to consent to search of his stuff

Defendant’s mother did not have actual or apparent authority to consent to a search of her adult son’s bedroom. He had been staying with her for four months and she came into the room with “regular access” to make the bed and clean up, but that wasn’t enough because it was apparent that the room was used by only her son. She consented to a search, and the police looked in a box with men’s clothes. Ward v. State, 88 So. 3d 419 (Fla. 4th DCA 2012).

Jail inventory policy was unconstitutional under the Oregon constitution because it had no limitations on search of containers objectively likely to hold contraband. State v. Taylor, 250 Ore. App. 90, 279 P.3d 254 (2012).*

Existence of an arrest warrant was justification for a stop. United States v. Nelson, 2012 U.S. App. LEXIS 9839 (3d Cir. May 16, 2012).*