State v. Byseem T. Coles (070653), 95 A.3d 136

Defendant Byseem Coles, nearly 20, lived in his aunt’s Camden home with his own bedroom secured by a padlock.
On March 18, 2008, police detained Coles during a robbery investigation after a showup failed to identify him.
Police sought to confirm identity and residence and obtained aunt’s consent to search Coles’s bedroom.
The search uncovered weapons unrelated to the robbery.
Trial court denied suppression; the Appellate Division reversed, focusing on lack of common authority and unlawful detention.
State granted certification to review whether the third‑party consent search was permissible under state and federal law.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Ms. Coles had authority to consent to the search.	State contends Coles had common authority through aunt status and access to the room.	Coles lacked actual or apparent authority to consent to a search of Coles’s bedroom.	No; the Court holds the search was not objectively reasonable due to unlawful detention and lack of valid third‑party consent.
Whether the detention of Coles was lawful and justified continued investigation.	Detention based on reasonable suspicion and for brief identity verification was permissible.	Continued detention after failed showup lacked probable cause and was unlawful.	The detention became unlawful after the showup failed to identify Coles; this tainted the consent to search.
Whether the consent by Ms. Coles could be valid given unlawful detention and the total circumstances.	Consent was valid under common authority and objective reasonableness.	Consent premised on unlawful detention cannot be valid; Fernandez/Randolph controls.	Consent-based search invalid where detention was unlawful and premised the search.

United States v. Matlock, 415 U.S. 164 (U.S. 1974) (third-party with common authority may consent to search the premises)
Illinois v. Rodriguez, 497 U.S. 177 (U.S. 1990) (police reasonably believe third party has common authority; valid if reasonable belief)
Georgia v. Randolph, 547 U.S. 103 (U.S. 2006) (physically present co-occupant’s explicit objecting negates consent)
Fernandez v. California, 571 U.S. 292 (U.S. 2014) (objecting co-occupant must be present; absent absent occupant does not vitiate consent when absent)
State v. Suazo, 133 N.J. 315 (N.J. 1993) (third-party consent analyzed by objective reasonableness)
State v. Crumb, 307 N.J. Super. 204 (N.J. App. Div. 1997) (parental/third-party consent where authority over space is at issue)
State v. Domicz, 188 N.J. 285 (N.J. 2006) (consent searches evaluated by objective reasonableness and authority)
State v. Lamb, 218 N.J. 300 (N.J. 2014) (reaffirms Randolph/Fernandez framework for co-tenant consent)