Illinois v. Rodriguez

Facts

On July 26, 1985, police were called to the Chicago home of Dorothy Jackson. Her daughter, Gail Fischer, showed signs of a severe beating. Fischer said Edward Rodriguez had assaulted her earlier that day in an apartment on South California Avenue and was asleep there. She agreed to go with the police and unlock the door with her key so they could arrest him. She several times called it "our" apartment and said she had clothes and furniture there. It is unclear whether she said she currently lived there or only used to. The police had no arrest warrant and no search warrant. Fischer unlocked the door and let them in. In the living room they saw drug paraphernalia and containers of white powder, which proved to be cocaine. In the bedroom they found Rodriguez asleep and more containers in two open attaché cases. They arrested him and seized the drugs. The evidence showed that Fischer had lived with Rodriguez from December 1984 but had moved out on July 1, 1985, to live with her mother. She took her and her children's clothing but left some furniture and household effects. Afterward she sometimes spent the night there, but she never invited friends and never went when he was away. Her name was not on the lease, and she paid no rent.

Issues

1. Did the State show that Fischer had common authority over the apartment, so that her consent alone made the warrantless entry valid?
2. Did the Illinois Appellate Court's decision rest on an adequate and independent state ground that bars review by the Supreme Court?
3. Is a warrantless entry valid when it rests on the consent of a third party whom the police reasonably believe has common authority over the premises but who in fact does not?

Holding

Fischer lacked actual common authority, but a warrantless entry is not invalid on that ground alone if the officers reasonably believed she had it. The Illinois court erred in ruling as a matter of law that a reasonable belief could not validate the entry.