Najam, J.
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As a matter of first impression in Indiana, we hold that it is reasonable under the Fourth Amendment for an officer to rely on the voluntary consent of a minor’s parent to search the minor’s bedroom inside the parent’s home. Accordingly, we affirm the juvenile court’s adjudication of R.B. as a delinquent.
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… R.B.’s argument on appeal emphasizes that he had a “subjective and objective expectation of privacy” to his bedroom; that he “had a high degree of actual control and possession of his room”; that “[h]is bedroom was his own space”; that he “had to live at his mother’s house, or commit a delinquent act”; that T.B. “gave [him] a great deal of privacy”; and that “[his] expectation of privacy . . . is one society should see as justifiable under the circumstances.” Appellant’s Br. at 10-12. We think these arguments miss the point.
… As relevant here, “[t]he Fourth Amendment recognizes a valid warrantless entry and search of premises when police obtain the voluntary consent of an occupant who shares, or is reasonably believed to share, authority over the area in common with a co-occupant who later objects to the use of evidence so obtained.” Georgia v. Randolph, 547 U.S. 103, 106 (2006). [Other citations omitted; footnote omitted.]
That is what happened here. While R.B. did not consent to the search of the bedroom, his mother, the owner or renter of the house, did. There is no serious question that it is reasonable for an officer to rely on the voluntary consent of a minor’s parent to search the minor’s bedroom inside the parent’s home.
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… [T]he Randolph Court … stated: “people living together [who] fall within some recognized hierarchy, like a household of parent and child,” might have a “societal understanding of superior and inferior” rights to use and enjoy the property. Id. That is of course the case with respect to minors in their parents’ homes. The “widely shared social expectations” in such circumstances are that the parents have unilateral authority over and access to the home. See id. at 111, 114. Accordingly, like numerous other jurisdictions, we reject R.B.’s argument that his mother’s consent does not supersede his. [Citations omitted; footnote omitted.]
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Affirmed.
Kirsch, J., and Barnes, J., concur.