In Florida v. Jimeno (1991) 500 U.S. 248, a police officer stopped a vehicle for a moving violation and informed the defendant, who was the driver, that he suspected the defendant was carrying narcotics in the car. The defendant gave consent to search the car. The officer opened the passenger side door, and saw a folded, brown paper bag on the floorboard. He picked up the back, opened it, and found a kilogram of cocaine inside. (Jimeno, supra, 500 U.S. at pp. 249-250.) Jimeno held the driver's "general consent to a search of his car" reasonably could be understood to include within its scope the search of a closed paper bag. (Jimeno, supra, 500 U.S. at p. 251.) Jimeno held the standard for measuring the scope of consent is to ask "what would the typical reasonable person have understood by the exchange between the officer and the suspect." (Ibid.) "The scope of a search is generally defined by its expressed object. In this case, the terms of the search's authorization were simple. The defendant granted the officer permission to search his car, and did not place any explicit limitation on the scope of the search. The officer had informed the defendant that he believed the defendant was carrying narcotics, and that he would be looking for narcotics in the car. We think that it was objectively reasonable for the police to conclude that the general consent to search the defendant's car included consent to search containers within that car which might bear drugs. A reasonable person may be expected to know that narcotics are generally carried in some form of a container. 'Contraband goods rarely are strewn across the trunk or floor of a car.' The authorization to search in this case, therefore, extended beyond the surfaces of the car's interior to the paper bag lying on the car's floor." (Id. at p. 251.) Jimeno cautioned that the defendant's consent probably would not extend to a locked briefcase in the trunk of the car, but it rejected the defendant's contention that the police must request separate permission to search each container in the area to be searched. (Jimeno, supra, 500 U.S. at pp. 251-252.) Jimeno found no basis for adding such a requirement: "A suspect may of course delimit as he chooses the scope of the search to which he consents. But if his consent would reasonably be understood to extend to a particular container, the Fourth Amendment provides no grounds for requiring a more explicit authorization." (Id. at p. 252.) In Florida v. Jimeno (1991) 500 U.S. 248, the high court explained that the scope of consent usually is defined by the expressed object of the search. In that case, where a police officer stopped a vehicle, informing the occupant of the officer's suspicion that the vehicle contained narcotics, the driver's consent to a search of the vehicle reasonably could be understood to include within its scope the search of a closed paper bag discovered within the vehicle. The court reasoned that despite being informed that the officer would be looking for narcotics, the defendant "did not place any explicit limitation on the scope of the search." (Ibid.) The court concluded, "We think that it was objectively reasonable for the police to conclude that the general consent to search respondent's car included consent to search containers within that car which might bear drugs. A reasonable person may be expected to know that narcotics are generally carried in some form of a container. . . . The authorization to search in this case, therefore, extended beyond the surfaces of the car's interior to the paper bag lying on the car's floor." (Ibid.) Although the court warned that the defendant's consent probably would not extend to a locked briefcase in the trunk of the car, the court rejected the defendant's contention that the police must request separate permission to search each container in the area to be searched. (Id. at pp. 251-252.) In sum, police officers, after having obtained consent to search Jimeno's car for narcotics, found cocaine in a folded paper bag lying on the floor of the front-seat passenger's side (see Florida v. Jimeno, 500 U.S. at 249-250). The Florida state courts suppressed the narcotics, applying "a per se rule that consent to a general search for narcotics does not extend to sealed containers within the general area agreed to by the defendant" (id. at 250). Notably, the Supreme Court rejected the per se approach of the Florida courts, an approach indistinguishable from the path taken by the majority today. In rejecting application of a per se rule, the Jimeno Court explained that "the Fourth Amendment is satisfied when, under the circumstances, it is objectively reasonable for the officer to believe that the scope of the suspect's consent permitted him to open a particular container within the automobile" (id. at 249). The scope of a suspect's consent hinges on "what would the typical reasonable person have understood by the exchange between the officer and the suspect" (id. at 251). Further, "the scope of a search is generally defined by its expressed object" (id.). In Florida v. Jimeno, the United States Supreme Court held that when an officer explains that he is searching for narcotics, a general consent to search a car permits examination of a folded brown paper bag on the floor of the vehicle (see Jimeno, 500 U.S. at 251). The Court noted, however, that "it is very likely unreasonable to think that a suspect, by consenting to the search of his trunk, has agreed to the breaking open of a locked briefcase within the trunk" (Jimeno, 500 U.S. at 251-252).