identified the bag as belonging to the appellant. These facts prove that the appellant retained an objectively reasonable expectation of privacy in the bag. Once a defendant establishes that he had a reasonable expectation of privacy in an item and that the police searched it without a warrant, the burden shifts to the Commonwealth to prove that an exception to the warrant requirement rendered a search of the item reasonable. See, e.g., Megel v. Commonwealth, 262 Va. 531, 534, 551 S.E.2d 638, 640 (2001). The Commonwealth contends here that the appellant’s girlfriend had authority to consent to a search of the appellant’s bag and in fact did so. A consent search by law enforcement officers may be “reasonable when conducted pursuant to voluntary t. 1420, 1425, 22 L.Ed.2d 684 (1969) (<HOLDING>). If actual authority is lacking, apparent
holding that it was objectively reasonable for the police to conclude that the general consent to search the respondents car included consent to search a bag within that car holding that where a defendant left his duffel bag at his cousins house and authorized the cousin to use the bag the cousin clearly had authority to consent to its search holding that girlfriend lacked actual or apparent authority to consent to the search of her boyfriends bag which he stored in her apartment because she identified the bag as his and no evidence indicated that she exercised mutual use or possessed  joint interest and control over it holding that search of shoulder bag was not authorized by search warrant for apartment holding that the owner of a shoulder bag located on the front seat of his girlfriends car had a legitimate expectation of privacy in the bag and its contents