Which 2014 Supreme Court decision clarified consent searches in the Georgia v. Randolph line of cases?

• A. Fernandez v. California
• B. Miranda v. Arizona
• C. Mapp v. Ohio
• D. Terry v. Ohio

Answer: (A)

Consent searches hinge on who is present and who is willing to allow the search. In Georgia v. Randolph, the Court ruled that when both occupants are present and one consents while the other objects, the objecting occupant’s privacy interest overrides and the police cannot search without a warrant or the objector’s consent. The 2014 decision Fernandez v. California clarified this rule by addressing what happens if the objecting occupant is not present at the time of the search. If the objector has been separated from the scene, the remaining occupant’s consent can authorize the search, and the earlier objection doesn’t bar the search. This resolves the situation when one co-occupant’s objection would otherwise block a search that another occupant validates through consent, provided the objector is not present to object.

The other options deal with different topics: Miranda v. Arizona concerns interrogation rights, Mapp v. Ohio concerns the exclusionary rule, and Terry v. Ohio concerns stop-and-frisk.