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In recent years, the Supreme Court has abandoned exclusive reliance on property concepts in deciding whether certain police searches violate the fourth amendment; instead it has increasingly recognized the privacy rights of individuals.' As a concept of general applicability, privacy has been defined as the "ability of the actor to maintain the integrity of his privacy unit."2 One commentator has described control over the privacy unit as "the legally recognized freedom or power of an individual (group, association, class) to determine the extent to which another individual (group, association, class, or government) may... obtain or reveal information about him or those for whom he is personally responsible, or . . . intrude physically or in more subtle ways into his life space and his chosen activities.";2 Although privacy concepts have been used in the fourth amendment area to define when the government can unilaterally intrude upon an individual's interests, 4 they have not been applied to the question of when one individual can validate a governmental intrusion upon another individual's interests. That question is presented in its most difficult form when two people share a possessory interest in property, and one consents to a police search directed against the other. Most courts have held that the first person can consent if he has a possessory interest in the property equal or superior to that of the person whose actions are the focus of the search.5 A pure property test, however, fails to reflect the Supreme Court's recognition that an individual's fourth amendment protections should not be dependent solely upon his property interests.

Third-Party Consent Searches: An Alternative Analysis