547 U.S. 103 (2006) (U.S. Supreme Court)
Georgia v. Randolph is a cornerstone Fourth Amendment case that refines the consent-search doctrine for shared residences.
Whether, under the Fourth Amendment, police may conduct a warrantless search of a shared residence based on the consent of one co-occupant when another co-occupant is physically present and expressly refuses to consent.
A warrantless search of a shared residence based on one co-occupant's consent is invalid as to a physically present co-occupant who expressly refuses consent, absent another exception (e.g., exigent circumstances); consent by a co-occupant may suffice when the objecting occupant is absent (Matlock) or where officers reasonably rely on apparent authority (Rodriguez).
When a physically present co-occupant expressly refuses consent, another occupant's consent does not justify a warrantless search; such a search is unreasonable under the Fourth Amendment as to the objecting resident.
Randolph is a pivotal limitation on third-party consent searches. It instructs that co-occupant consent is not a blanket substitute for a warrant where another resident is present and expressly says no. For students, the case clarifies the interaction among three pillars of consent doctrine: (1) actual common authority (Matlock), (2) apparent authority (Rodriguez), and (3) the Randolph exception for simultaneous objection by a present resident. It also highlights the Court's use of social-expectations analysis to define reasonableness and preserves space for exigent circumstances. The case's practical importance is amplified by its later refinement in Fernandez v. California (2014), which held that if the objecting occupant is lawfully removed for objectively reasonable reasons (e.g., arrest supported by probable cause), the remaining occupant's consent can validate a subsequent search. Thus, Randolph's protection turns critically on physical presence and express objection at the time of the proposed entry.