In Illinois v.Rodriguez (1990),the police conducted the consent search of the suspect's apartment based on the consent of the suspect's former girlfriend.According to the Supreme Court's opinion:

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The Supreme Court held that a warrantless entry to search based on third party consent is valid if the officer reasonably believes that the person consenting had authority to consent. This means that as long as the officer has a reasonable belief that the third party has the authority to consent, the search will not violate the Fourth Amendment. In this case, the court found that the police officer had acted reasonably since the former girlfriend had recently lived with the suspect and still had a key to the apartment. Therefore, the consent search conducted by the police based on her consent was valid.

In Illinois V