In Illinois v. Rodriguez, 497 U.S. 177 (1990), officers searched an apartment with consent obtained from a woman who claimed to live there, had furniture and clothing there, and had a key, which she used to open the door for the officers. In reality, the woman had moved out a month earlier and was only an infrequent visitor. Although actual authority to consent was absent, the United States Supreme Court held that the search did not violate the Fourth Amendment because the officers' reliance on the woman's claimed authority over the apartment was reasonable under the circumstances. The Court noted that the Constitution requires only that the officers' belief in the consenter's authority be objectively reasonable, not that it be legally and factually correct. Therefore, in evaluating a claim that officers acted on the consent of a person with apparent authority, the proper inquiry is whether "the facts available to the officer at the moment . . . 'warrant a man of reasonable caution in the belief' that the consenting party had authority over the premises?" Rodriguez, 497 U.S. at 188. If not, a warrantless entry is unlawful unless actual authority exists. Rodriguez, 497 U.S. at 188-89The United States Supreme Court considered "whether a warrantless entry is valid when based upon the consent of a third party whom the police, at the time of entry, reasonably believe to possess common authority over the premises, but who in fact does not do so." Id. at 179. The Court noted that common authority rests "'on mutual use of the property by persons generally having joint access or control for most purposes . . . .'" Id. at 181 (quoting United States v. Matlock, 415 U.S. 164 (1974)). "The burden of establishing that common authority rests upon the State." Id. The Court in Rodriguez concluded that a warrantless entry may nonetheless be valid under the Fourth Amendment where the officer proceeds based upon a reasonable but mistaken belief that a third party has apparent authority to consent. See 497 U.S. at 188-89. The Court wrote: As with other factual determinations bearing upon search and seizure, determinations of consent to enter must be judged against an objective standard: would the facts available to the officer at the moment . . . warrant a man of reasonable caution in the belief that the consenting party had authority over the premises? If not, then warrantless entry without further inquiry is unlawful unless authority actually exists. But if so, the search is valid. 497 U.S. at 188-89. The Fourth Circuit has held that the good faith exception enunciated in Rodriguez does not "extend even beyond the generally recognized exceptions to the warrant requirement: i.e., beyond consent, or one of the various forms of exigency that have been recognized depending upon the purpose of the search." United States v. Moss, 963 F.2d 673, 677 (4th Cir. 1992). Thus, "the mistaken determinations of police officers that may be excused as good faith, reasonable ones, must yet be related to elements of one of these exceptions." Id. In Illinois v. Rodriguez, the court upheld a search pursuant to consent that the police obtained from a person they reasonably, but mistakenly, thought was a resident authorized to give it. The court cited and reaffirmed Hill, stating, "It is apparent that in order to satisfy the 'reasonableness' requirement of the Fourth Amendment, what is generally demanded of the many factual determinations that must regularly be made by agents of the government--whether the magistrate issuing a warrant, the police officer executing a warrant, or the police officer conducting a search or seizure under one of the exceptions to the warrant requirement--is not that they always be correct, but that they always be reasonable. As we put it in Brinegar v. United States 338 U.S. 160 (1949). . . 'Because many situations which confront officers in the course of executing their duties are more or less ambiguous, room must be allowed for some mistakes on their part. But the mistakes must be those of reasonable men, acting on facts leading sensibly to their conclusions of probability.' " (Illinois v. Rodriguez, supra, 497 U.S. at pp. 185-186.)