Illinois v. Rodriguez
Citation and Court
497 U.S. 177 (1990) — Supreme Court of the United States
Facts
Officers entered Rodriguez’s apartment with the consent of a woman who represented that she shared the apartment and had authority to consent. She did not in fact have common authority over the premises. Evidence was found inside and Rodriguez moved to suppress.
Issue
Whether a warrantless entry based on the consent of a third party who the police reasonably, but mistakenly, believed had authority to consent violates the Fourth Amendment.
Holding
The warrantless entry was valid; consent by a third party is sufficient if the officers reasonably believed that party had authority to consent, even if that belief turns out to be mistaken.
Rule / Doctrine
The apparent authority doctrine: a search is lawful if police reasonably rely on a third party’s apparent authority to consent, even if the third party lacks actual authority. The Fourth Amendment’s reasonableness requirement is satisfied by an officer’s objectively reasonable (though factually erroneous) belief.
Significance
Established the apparent authority doctrine for third-party consent, extending the reasonableness standard to factual mistakes about authority, consistent with the treatment of officer mistakes elsewhere in Fourth Amendment law.