can justify an earlier unconstitutional search if the person giving the consent so intends. Because the voluntary nature of Carole Hubbel’s “consent” is not at iss -Gonzalez (5th Cir. 1984), 727 F.2d 407, 414 (rejecting the argument that a written consent form which “simply came too late” vitiates a prior illegal search, because “[t]here is no authority which justifies an earlier illegal search based upon a later consent to an additional search.”); Mickelson v. State (Wyo. 1995), 906 P.2d 1020, 1022 (stating that efforts to establish consent after an illegal entry “ran afoul of the proposition that such action must be ‘justified at its inception.’”) (citing Terry v. Ohio (1968), 392 U.S. 1, 20, 88 S.Ct. 1868, 1879, 20 L.Ed.2d 889, 905); People v. Thiret (Colo. 1984), 685 P.2d 193, 201 (<HOLDING>). Unfortunately, the cases cited provide little
holding that the defendants consent to allow the officer to search her purse by way of holding it open for the officer was for consent to a limited view of the purses interior not to surrender possession  for an unrestricted search and thus the officer exceeded the scope of the defendants consent holding that a search exceeded the scope of the initial oral consent and was not validated by a subsequent written consent an allegedly consensual seizure must stand or fall on the basis of the consent preexisting the seizure holding that evidence was inadmissible because it was not within the scope of defendants oral preseizure consent to a cursory visual inspection and the seizure was conducted prior to not pursuant to the defendants written consent to conduct a complete search holding there is no consent as a matter of law where the consent was given under coercion holding that the defendants subsequent written consent given with the full knowledge that the police had previously entered his house without a warrant amounted to a waiver of the warrant requirement and rendered the earlier search and seizure valid