38 Ill.App.3d 616, 348 N.E.2d 277 (1976) (noting that a co-occupant of premises in which contraband is kept runs a significant risk of facing criminal charges and can, therefore, act in his own interest in the Matlock sense). 27 . Illinois v. Rodriguez, 497 U.S. 177, 186, 110 S.Ct. 2793, 111 L.Ed.2d 148 (1990). 28 . Rodriguez, 497 U.S. at 181, 110 S.Ct. 2793; Malone v. State, 163 S.W.3d 785, 797-98 (Tex.App.-Texarkana 2005, pet. ref’d). 29 . Maxwell, 73 S.W.3d at 281. Under the Texas Constitution, the State must show by clear and convincing evidence that consent was validly given. Id. 30 . State’s Brief on the Merits, at 4. 31 . State v. Ross, 32 S.W.3d 853, 856, n. 22 (Tex.Crim.App.2000). 32 . Hubert, 286 S.W.3d at 489. 33 . See Sorensen v. State, 478 S.W.2d 532 (Tex.Crim.App.1972) (<HOLDING>); Martinez v. State, 17 S.W.3d 677
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 mother had the authority to consent to search of defendants bedroom defendant lived with parents rentfree for four years mother owned the house appellants bedroom door was open mother knocked whenever appellants door was locked and there were no restrictions placed on mothers right to enter bedroom holding that twentyyearold appellants mother had authority to consent to a search of sons bedroom where appellant had agreed to pay 10 per week as rent he had not instructed mother to stay out of his room and mother infrequently entered appellants room to pick up after him holding that although son was eighteen years old and paid rent mother could consent to search of sons bedroom where nothing suggested mother lacked access to room holding that officers had a reasonable belief that defendants father had authority to consent to the search of his sons room and computer because he owned the home and had access to the room and computer at will