United States v. Matlock - Impact

In United States v. Matlock, the Supreme Court determined that third party consent to search a premises without a warrant was sufficient if the person "possessed common authority over or other sufficient relationship to the premises or effects sought to be inspected." The Court ruled in Illinois v. Rodriguez (1990) that actual common authority over a place is not required. It is sufficient if the officer had a reasonable but mistaken belief that the third party possessed common authority and could consent to the search. United States v. Matlock and Illinois v. Rodriguez illustrate the Supreme Court's growing interest in upholding warrantless searches as not "unreasonable" under the Fourth Amendment.