Watkins: Husband's limited Consent does not vitiate wife's full consent

In U.S. v. Watkins, No. 12-12549 (July 28, 2014), the Court held that Georgia v. Randolph, which held that, under the Fourth Amendment, the contemporaneous objection of a person who shared common authority over a home prevented a search when one person with authority had consented, the fact that defendant had given only a limited consent to a search of his computers did not vitiate the valid, full consent that his wife gave to search these computers – a search that uncovered child pornography images. The Court noted that the defendant did not voice any objection when his wife consented to the search. His actions fell “well outside Randolph’s conception of an objection.” The Court pointed out that Randolph created only a “narrow exception” to the doctrine that a person with common authority over premises has authority to consent to a search.