context: It is the disputed portion of the premises which could not be searched in the absence of "joint access or control for most purposes" over them by Ms. Bakker. Mr. Kelley's privacy interest in his bedroom is not diminished by the fact that Ms. Bakker had access to other areas of the apartment; similarly, the police may not search a bedroom merely because other areas of the apartment may lawfully be searched. Precedent makes clear that Ms. Bakker could validly consent to a warrant-less search of Mr. Kelley's bedroom only if she had "joint access and control for most purposes" over the bedroom itself.
citation_a.signal: see also
citation_a.identifier: 503 F.2d 1288, 1288
citation_a.parenthetical: holding consent invalid when a housemate had unlimited access to the common areas of the apartment but only limited access to her housemate's bedroom
citation_a.sentence: See Cunningham, 352 F.2d at 4-5 (noting that the validity of consent is analyzed according to the particular area to be searched and the extent of the housemate’s access to that particular area); see also Heisman, 503 F.2d at 1288 (holding consent invalid when a housemate had unlimited access to the common areas of the apartment but only limited access to her housemate’s bedroom).
citation_b.signal: see
citation_b.identifier: 352 F.2d 4, 4-5
citation_b.parenthetical: noting that the validity of consent is analyzed according to the particular area to be searched and the extent of the housemate's access to that particular area
citation_b.sentence: See Cunningham, 352 F.2d at 4-5 (noting that the validity of consent is analyzed according to the particular area to be searched and the extent of the housemate’s access to that particular area); see also Heisman, 503 F.2d at 1288 (holding consent invalid when a housemate had unlimited access to the common areas of the apartment but only limited access to her housemate’s bedroom).