in the room — a fact that the officers plainly conceded they knew at the time of the search — has some tendency to show that Reed did not have mutual use of the appellant’s bedroom. However, the determination of whether a person has authority to consent to a search of another person’s bedroom cannot rest solely on this factor — ie., whether that third p ll.Dec. 856, 597 N.E.2d 830, 837 (1992). See also State v. Cole, 706 S.W.2d 917 (Mo.Ct. App. 1986) (explaining that a person living with his family can expect more intrusion that an independent renter living with non-relatives). 36 . Bliey, 173 Ill.Dec. 856, 597 N.E.2d at 837. 37 . See generally 4 Wayne R. LaFave, Search and Seizure, § 8.5(c) (4th ed. 2004 & Supp. 2009). 38 . See United States v. Jimenez, 419 F.3d 34, 40 (1st Cir.2005) (<HOLDING>); People v. Mullaney, 104 Mich. App. 787, 306
holding that while a mother could consent to a search of her sons room she did not have authority to consent to a search of a locked footlocker within the room holding that appellants father had authority to consent to search of defendants bedroom where house defendant lived in was owned by his parents room was not locked and defen dants family was not denied access to bedroom holding that as owner of the residence the grandfather had actual authority to consent to a search of the defendants bedroom because there was no evidence that grandfather lacked authority to enter defendants room and because defendants bedroom did not have a lock or anything restricting access to the room the court found that the grandfather shared common authority over the bedroom holding that a lessee of a home could not consent to a search of a bedroom that was used exclusively by a temporary gratuitous guest because the guest had an expectation of privacy in the bedroom holding that the lessee of an apartment where defendant was residing could not consent to a search of the defendants room where the lessee characterized defendants bedroom as his space and said she did not enter the room as a regular matter