In People v. Oldham (2000) 81 Cal.App.4th 1, the defendant objected that his father's consent for the police to search the family apartment was not valid, but did not raise any distinct legal theory as to why the search of closed containers within the apartment was improper. The Fourth District Court of Appeal found that the defendant had waived his claim that the search of the closed containers was improper. ( Id. at pp. 14-15.)