In State v. Farrell, 443 A.2d 438 (R.I. 1982), the defendant left a vehicle at a local garage, having authorized repairs to a dent on the left front fender of the car.

A stolen vehicle investigation led police to the garage where defendant had dropped off his vehicle. An examination of the vehicle identification number of the defendant's vehicle revealed that the vehicle was stolen.

At this point, an officer asked the owner of the garage for permission to tow the car to the police station. After some discussion, the owner of the garage consented.

The trial court rejected the defendant's contention that the owner of the garage had no authority to consent to the car being impounded.

The appellate court held that the trial court should have granted the motion for suppression, explaining:

The doctrine that recognizes the validity of third party consent to a search must be applied cautiously to prevent erosion of the Fourth Amendment protections.