Which 2014 US Supreme Court decision brought clarity to Georgia v. Randolph and consent searches?

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

Answer: (C)

Consent searches of a shared residence hinge on whether the other occupant is present to object. Georgia v. Randolph held that if both people are present and one objects, the police cannot rely on the consenting occupant’s permission to search. Fernandez v. California then clarifies that when the objecting occupant is not present at the time of the search, the other occupant’s consent can authorize a valid search. In Fernandez, the police searched the apartment with the present roommate’s consent while the objecting resident was away; the Court ruled that Randolph does not bar that search because there was no one present to object. This clarifies how to apply consent in shared dwellings: presence and objection matter, but consent from a present occupant can be valid if the other occupant isn’t there to object.

The other cases don’t focus on this specific consent-and-occupant dynamic. Miranda deals with interrogation rights, Mapp with the exclusionary rule in general, and Terry with stop-and-frisk.