Casey Walker v. State of Indiana, 986 N.E.2d 328

Walker was convicted of class A felony manufacturing methamphetamine and sentenced to 30 years; trial included warrantless entry based on Jennifer and Mary's consent.
Mary Walker, Walker’s mother, owned/resided in the home and allegedly had Alzheimer’s; Walker argued she was incompetent to consent.
Police obtained verbal consent from Jennifer and Mary to enter the residence and a consent form signed by Mary and Baumgartner.
Officers entered, conducted a protective sweep, detected meth-associated odor and items, obtained a search warrant, and recovered meth-related evidence.
Walker challenged suppression on multiple grounds (consent validity, warrant breadth, knock-and-announce), but the trial court denied suppression and he was convicted.
The Court of Appeals affirmed, holding that Mary’s competency was not proven to be lacking and Jennifer had common authority to consent.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Mary competent to consent to the search?	Walker argued Alzheimer’s rendered Mary incompetent.	State contends Mary was competent; no guardianship shown.	Mary competent; consent valid.
Did Jennifer have authority to consent as a co-occupant?	Walker questioned Jennifer’s authority to consent.	State says Jennifer had common authority to consent.	Jennifer's consent valid; not improper under Randolph.
Was the admission of evidence from the warrantless entry permissible?	Walker sought suppression of evidence; police lacked valid consent.	State prevailed; consent valid and search proper.	Evidence admissible; trial court did not err.

Georgia v. Randolph, 547 U.S. 103 (2006) (co-tenant consent cannot override explicit objection)
Hill v. State, 825 N.E.2d 432 (Ind. Ct. App. 2005) (common authority to consent requires joint access/control)