United States v. Rodriguez, 888 F.2d 519, 523 (7th Cir. 1989).Dorian argues Shelly lacked apparent authority based on State v. Sobczak, 2013 WI 52, ¶20, 347 Wis. 2d 724, 833 N.W.2d 59, which identified three factors that are especially relevant to apparent consent of invited guests: (1) the relationship of the consenter to the property owner, including familial connections and social ties; (2) the duration of the consenter’s stay; and (3) whether the consenter was permitted to be at the property alone. The court disagrees.

No: none. Beyond the citation quoted above, the majority drops a footnote (¶28 n.20) spurning the dissent’s reliance on Riley, Carroll, and State v. Sobczak, 2013 WI 52, 347 Wis. 2d 724, 833 N.W.2d 59, for the proposition that the seizure of an electronic device is distinct from a subsequent search of its contents (¶¶41-48). After reiterating Purtell was a probationer with diminished privacy interests, the majority merely notes that these cases, “while interesting, are of minimal assistance to our analysis.”

State v. Kenneth M. Sobczak, 2013 WI 52, affirmingpublished court of appeals decision; case activity; majority opinion by Justice Gableman; Chief Justice Abrahamson and Justice Bradley dissent.In a significant expansion of the third-party consent doctrine, the supreme court holds that a weekend guest may grant consent to police to enter her host’s home and conduct a search. The court concludes the rule governing third-party consent articulated in United States v. Matlock, 415 U.S. 164 (1974), Illinois v. Rodriguez, 497 U.S. 177 (1990), and Georgia v. Randolph, 547 U.S. 103 (2006), is not limited to “co-occupants” or “co-inhabitants” and does not draw a bright line focused solely on the duration of the person’s stay in the home.