In Bumper v. North Carolina, 391 U.S. 543 (1968), the police gained the consent of the defendant's grandmother to search the home based on a false claim that they had a warrant to search the house. Id. at 546. No warrant was ever obtained nor presented to either the defendant or his grandmother; rather, the State explicitly argued at trial that the grandmother had voluntarily consented to the search, such that a warrant was unnecessary. Id. at 547-48. The Supreme Court therefore held that, "When a law enforcement officer claims authority to search a home under a warrant, he announces in effect that the occupant has no right to resist the search. The situation is instinct with coercion-albeit colorably lawful coercion. Where there is coercion there cannot be consent." Id. at 550. In Bumper v. North Carolina, one of several law enforcement officers had asserted, "I have a search warrant to search your house," and the resident subsequently opened her door to permit entry. 391 U.S. at 546. The dissent maintained that the search should be upheld because the totality of the circumstances suggested nonetheless that she had invited the officers to search of her own free will and had no objection to it. Id. at 555-56 (Black, J., dissenting). The majority, however, declined to consider such factors in its analysis. See id. at 547-48 & 547 n.8. In so doing, the Court construed a person's acquiescence to a claim of authority as showing an intent to abide by the law; it is not interpreted as a waiver of rights, but rather as a submission to lawful authority. See id. at 549 n.14. In Bumper v. North Carolina, the state argued a home search was consensual, but the person who gave consent stated at the hearing that one of the officers "walked up and said, 'I have a search warrant to search your house,'" before she let them in. Id. at 546. There was no evidence in the record that the officer had a search warrant. Id. at 549-50. Although the court noted the state's assertion at argument "that the searching officers did, in fact, have a warrant," it never was returned and, therefore, could not be evaluated or considered. Id. at 550 n.15. The Supreme Court concluded that a prosecutor cannot prove consent was voluntary by "showing no more than acquiescence to a claim of lawful authority." Id. at 548-49. The Court held that an officer who says he has a warrant "announces in effect that the occupant has no right to resist the search." Id. at 550.