667 N.E.2d 323, 326-27 (1996); Riordan v. State, 905 S.W.2d 765, 771 (Tex. App.1995); State v. Kieffer, 217 Wis.2d 531, 577 N.W.2d 352, 359-60 (1998). I agree. We have often noted that the touchstone of the Fourth Amendment is reasonableness. See, e.g., Bryant, 39 Va.App. at 471-72, 573 S.E.2d at 335; Weathers v. Commonwealth, 32 Va.App. 652, 658, 529 S.E.2d 847, 850 (2000). Considering the heightened expectation of privacy that exists in closed contain ers, I believe that, when permitted by the circumstances, “reasonableness” requires officers acting under third-party consent to make reasonable attempts to resolve any apparent ambiguity in the ownership or control over any closed containers located within the place being searched. See Rodriguez, 497 U.S. at 188-89, 110 S.Ct. at 2801 (<HOLDING>). Hence, absent some affirmative indicia that
holding that when law enforcement officers obtain consent to search pursuant to apparent authority if the surrounding circumstances are such that a reasonable person would doubt that authority exists and not act upon the consent without further inquiry  then the warrantless search without further inquiry is unlawful unless authority actually exists emphasis added holding search not to violate fourth amendment where officers belief that apparent landlord had the power to consent and that he had not revoked that consent was reasonable emphasis added holding that child residents had no actual or apparent authority to consent to search of mothers home holding that it was unreasonable to believe that womans boyfriend had authority to consent to the search of her purse even though he had authority to consent to the search of the car in which it was kept holding that defendants consent was involuntary where defendant consented to search following a warrantless entry and officers explained that absent consent the officers would obtain a warrant