In what circumstances will the court allow the police to search a bedroom without the consent of a third party?

Relying on decisions from a number of federal and state courts of appeal, Alcantar argues that, in circumstances where authority is ambiguous, the police have a duty to make inquiries into the circumstances of occupancy before relying on a third person's apparent authority. These courts have generally held that "[l]aw enforcement officers cannot use the apparent authority doctrine to justify a warrantless search when they fail to make a sufficient inquiry into the consenting party's 'use, access, or control over' the area to be searched." (Lastine v. State (Nev. App. 2018) 429 P.3d 942, 950.) "When faced with a situation . . . in which the suspect in a crime is located within a private area of a home such as a bedroomnot in a common areaand law enforcement officers choose to enter the private area without the consent of the person occupying the private area, but with the consent of a third party, they need to ensure the third party has the authority to allow the intrusion." (Ibid.; see also U.S. v. Cos (10th Cir. 2007) 498 F.3d 1115, 1128 [" '[W]here an officer is presented with ambiguous facts related to authority, he or she has a duty to investigate further before relying on the consent.' "]; U.S. v. Arreguin (9th Cir. 2013) 735 F.3d 1168, 1176 ["[T]he 'police are not allowed to proceed on the theory that ignorance is bliss' . . . They knew far too little to hold an objectively reasonable belief that [the third party] could consent to a search of those areas."].)