California, United States of America
The following excerpt is from People v. Williams, 114 Cal.App.3d 67, 170 Cal.Rptr. 433 (Cal. App. 1980):
In this case the officers did not rely on the automobile exception or upon any other stated exigency to justify the search and seizure. The officers relied upon defendant's consent. A voluntary consent to search creates a separate and independent exception to the warrant requirement and justifies a warrantless search of all areas covered by the consent over which defendant had authority. (See People v. Cruz (1964) 61 Cal.2d 861, 40 Cal.Rptr. 841, 395 P.2d 889.)
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