Independent Evaluation of 3rd Party Consent to Search Containers Separate from Premises

Apparent authority for third party consent requires the court to> independently evaluate the consent's authority over containers onthe> premises separate from the premises. Authority over containers maybe> obviously or apparently limited. United States v. Smairat, 2007 U.S. Dist.> LEXIS 57769 (N.D. Ill. August 8, 2007)