What is the test for obtaining consent for a search of a house by a police officer following a domestic violence incident?

The factual circumstances in United States v. Long, supra, are strikingly similar to those in the case at bar. Here Heather was forced out of the home she had shared with appellant out of fear for her safety. She moved to a temporary residence at a battered women's shelter after appellant had assaulted her and been physically abusive toward her. Appellant did not have exclusive right of possession of the house. They were still married and, at least at that point, appellant had no legal right to exclude her. (Compare Wisconsin v. Verhagen (App.1978) 86 Wis.2d 262, 272 N.W.2d 105 [wife's consent was not valid where divorce orders had awarded searched premises to the defendant].) As appellant's spouse, she remained liable for the rent or for accidents occurring on the property despite her absence. And although Heather took a substantial amount of personal property out of the home in her initial move and intended to abandon the premises, a substantial amount of her and her children's property remained in the house at the time of the officer's subsequent search. The fact appellant had changed the locks to the house is indicative of the level of antagonism between Heather and appellant but is not determinative of Heather's continuing authority in her own right to consent to a search of the house. (United States v. Long, supra, 524 F.2d at p. 661; United States v. Lawless, supra, 465 F.2d at p. 423.)