The following excerpt is from U.S. v. Elliott, 50 F.3d 180 (2nd Cir. 1995):
Applying Illinois v. Rodriguez, we have determined that it is not reasonable for police to believe that a landlord who enters an apartment for the purpose of switching off electrical appliances from time to time has common authority with the tenant over the leased premises. United States v. Brown, 961 F.2d 1039, 1041 (2d Cir.1992) (per curiam).
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