In Matlock, consent to search was granted by the co-occupant, who was on the premises while the defendant was detained in a police car nearby. Matlock, 415 U.S. at 166, 94 S.Ct. 988; Randolph, 547 U.S. at 109-10, 126 S.Ct. 1515. Ultimately, the Court determined that “the consent of one who possesses common authority [or other sufficient relationship] over premises or effects is valid as against the absent, noneon-senting person with whom that authority is shared.” Matlock, 415 U.S. at 170-71, 94 S.Ct. 988; see Gallagher, 66 M.J. at 253; United States v. Rader, 65 M.J. 30, 30-31 (C.A.A.F.2007). Common authority over a home extends to all items within the home, unless the item reasonably appears to be within the exclusive domain of the third party. Gallagher, 66 M.J. at 253-54 (<HOLDING>). Additionally, common authority can be
holding that conduct fell within the scope of employment even if it may have been overzealous or one sided holding that the challenged item was within the scope of the search because it reasonably fell within the expressed object of the search even though it turned out to be the defendants personal property holding an arbitration tribunal fell within the purview of section 1782 holding that an unlocked briefcase located within an attached garage which had been converted into a den fell within the common authority of appellants wife holding that bad faith handling of an insureds claim fell within the act