United States v. Matlock

United States v. Matlock

United States Supreme Court
415 U.S. 164 (1974)

TAG: "Matt, lock the door because a third party can give consent!"
ISSUE: Was the government's showing of 3rd party consent to search the premises constitutionally sufficient to render the evidence found therein admissible at trial?
HOLDING: Yes.
FACTS:
  • D was arrested for robbing a federally insured bank in his front yard
  • D lived with Graff, Graff's son, and Graff's parents in the house
  • Graff admitted the officers into the home where they asked if they could search and she consented
PROCEDURAL HISTORY:
  • Dist. Ct. concluded that the Govt. didn't show that Graff had actual authority to consent to the search
    • Ct. held that Graff's statement that she and D occupied the east bedroom was extrajudicial and thus inadmissible
  • Ct. App. affirmed
REASONING:
  • 3rd party consent valid: Prosecution may justify a warrantless search by proof of voluntary consent obtained from a 3rd party who possessed common authority over or other sufficient relationship to the premises and effects sought to be inspected
    • Sufficiency of consent rests on mutual use of the property by persons generally having joint access or control for most purposes so that it is reasonable to recognize that any of the co-inhabitants has the right to permit the inspection in his own right
  • Graff's consent sufficient: Graff's statement is admissible, and thus the Govt. proved her voluntary consent and authority over the premises

DISSENT - Douglas: The absence of a search warrant is fatal

DISSENT - Brennan: It must be shown that Graff consented knowing that she could refuse consent

COMMENTS:
  • While a third party possessing "common authority" over the premises to be searched can grant consent, see Georgia v. Randolph for a (small) limitation (i.e., when two cotenants are physically present at the threshold to the premises and one is refusing consent while the other is granting consent -- the refusal of consent wins out).
  • If an officer is mistaken about whether an individual possesses "common authority" over the premises, the search is still valid if the mistake is objectively reasonable (see Illinois v. Rodriguez).
NOTES:
  • Florida v. Jimeno: Scope of a consent search is governed by a standard of objective reasonableness
    • What would a reasonable person have understood by the exchange between the officer and the suspect?
    • Thus "May I search your car?" means definitely passenger compartment and trunk + what else (engine block, gas tank, etc.)?
    • A sign on a roommate's door saying that the other can't give consent limits the scope of the consent search, not the search itself

 

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