State v. Buie, 312 Conn. 574

Victim (LB) was assaulted in her apartment; defendant Buie and Beverly Martin were identified as assailants. Police later located Buie outside his apartment and Martin at the scene.
Martin told officers she needed to retrieve personal items from Buie’s apartment and volunteered, "I suppose you guys want to come with me," prompting officers to accompany her inside for officer safety.
While accompanying Martin, officers observed items they believed related to the assault; they then secured the apartment and later obtained a search warrant, which led to recovery of sex toys, BB guns, duct tape, and other items used at trial.
Buie moved to suppress evidence seized from his apartment, arguing Martin lacked authority to consent and police therefore violated his state and federal constitutional rights; the trial court denied the motion, finding the officers reasonably believed Martin had common authority.
Buie was convicted of multiple sexual assault–related offenses; on appeal he argued, for the first time, that Connecticut’s constitution (art. I, § 7) does not permit the federal "apparent authority" consent doctrine and requires actual authority.
The Appellate Court rejected Buie’s state-constitutional challenge after applying the Geisler factors; the Connecticut Supreme Court affirmed, adopting the Appellate Court’s reasoning and clarifying the standard.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the apparent authority doctrine (warrantless entry based on reasonable belief that a third party has common authority) is permissible under article first, § 7 of the Connecticut Constitution	State: Apparent authority is a valid exception; officers may rely on a reasonable, objective belief that a third party has common authority	Buie: Connecticut Constitution requires actual legal authority to consent to entry of a private home; apparent authority is insufficient	Held: Apparent authority is consistent with art. I, § 7 when officers reasonably (objectively) believe the third party has common authority; courts must evaluate reasonableness and an appropriate/diligent inquiry under the circumstances

Illinois v. Rodriguez, 497 U.S. 177 (1990) (establishes federal apparent authority doctrine allowing warrantless entry when officers reasonably believe a third party has common authority)
Georgia v. Randolph, 547 U.S. 103 (2006) (co-occupant’s present objection precludes entry based on another occupant’s consent)
State v. Golding, 213 Conn. 233 (1989) (procedural rule for reviewing unpreserved constitutional claims)
State v. Geisler, 222 Conn. 672 (1992) (six-factor framework for comparing state and federal constitutional protections)
State v. Davis, 283 Conn. 280 (2007) (recognition that the state constitution can provide broader privacy protections than federal law)
State v. Miller, 227 Conn. 363 (1993) (article first, § 7 requires warrant for certain searches—example of broader state protection)
State v. Marsala, 216 Conn. 150 (1990) (good-faith exception narrower under article first, § 7)
State v. Dukes, 209 Conn. 98 (1988) (search-incident-to-arrest exception narrower under state constitution)
In re Michaela Lee R., 253 Conn. 570 (2000) (discusses zones of privacy and state constitutional protections)
Commonwealth v. Porter P., 456 Mass. 254 (2010) (Massachusetts adopts apparent authority only when reasonable mistake occurs despite diligent police inquiry)