to search a particular container if “[a suspect’s original] consent would reasonably be understood to extend to [that] particular container.” Jimeno, 500 U.S. at 252, 111 S.Ct. at 1804. As Professor Wayne R. LaFave has observed in the context of premises searches, “the boundaries of the place referred to mark the outer physical limits of the authorized search.” 3 Wayne R. LaFave, Search and Seizure § 8.1(c), at 612 (3d ed.1996). I see no reason why this principle should not apply equally to searches of the person. Here, appellant’s express consent applied only to a search of “his person.” “The burden was upon the officer to obtain consent [covering the bag he wished to search], not on [appellant] to affirmatively deny consent.” Jean-Laurent, 34 Va. App. at 80, 538 S.E.2d at 319 (<HOLDING>). The mere fact that the object of the
holding tacit consent to search of person was insufficient to prove consent to search bags where bags were not in defendants actual possession defendant merely pointed out bags at officers request and officer never specifically asked for consent to search bags holding that random searches of subway passengers carryon bags which include the visual inspection of the contents of such bags to be minimal 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 of bags carried onto an airplane was minimally intrusive holding that defendant had no reasonable expectation of privacy in the contents of plastic bags placed in or near his open garbage cans and that the police did not violate his fourth amendment rights in seizing and searching the bags where they were able to do so without trespassing on the defendants property