People v. Goforth

In People v. Goforth, 222 Mich App 306, 310; 564 NW2d 526 (1997), the defendant's mother allowed the police officers to enter her house to search for a missing girl and the officers found incriminating evidence in the eighteen-year-old defendant's bedroom. Id. at 307-308. The trial court ruled that the mother's consent was invalid because the officers did not act reasonably in believing the defendant's mother had common authority over the defendant's bedroom. Id. at 308-309. The trial court cited the mother's testimony that the defendant had a "keep out" sign on his door, that the door was closed, and that the defendant never allowed anyone in his room. Id. at 309. The Court reversed, finding that the defendant's mother consented to the officers' search of the house and there was no indication that she lacked access to the defendant's bedroom or that the defendant had exclusive access to the room. Id. at 316-317.