May Police Conduct a Warrantless Search If Only One of the Property Owners Consents ?

In People v. Cosme 48 N.Y.2d 286, 422 N.Y.S.2d 652, 397 N.E.2d 1319 (1979), the Court of Appeals held that the police may conduct a warrantless search of a premises or personal property in which two or more individuals share a common right of access to or control of the property to be searched when they have obtained the voluntary consent of any one of the parties having authority to consent to the search. "An individual who possesses the requisite degree of control over specific premises is vested in his own right with the authority to permit an official inspection of such premises and this authority is not circumscribed by any 'reasonable expectation of privacy' belonging to co-occupants" and the defendant "has no right to prevent a search in the face-of knowing and voluntary consent of a co-occupant with equal authority." Cosme at page 292.