Fernandez (and four of his fellow gangstas) robbed some guy at knife point. During the robbery, the victim was cut, beated, and divested of $400 cash and a cell phone. Two officers who were searching for the robbery suspect saw someone run into an apartment building and subsequently heard screaming and fighting coming from inside one of the apartments. They waited for backup, and then knocked on the door.
A female answered the door, looking like she had been beated. She was crying, had fresh injuries, there was blood on her shirt, and she said she had been in a fight (she was also holding a baby and told police that there was a four year old in the apartment with her).
Officers asked the female (Rojas) to step out of the apartment so they could conduct a protective sweep. Fernandez then came to the door wearing his boxers. He angrily told police that he knows his rights and that they could not enter the apartment. The cops removed him from the apartment and arrested him for domestic violence. Then the original robbery victim identified Lopez as the one who had robbed him, and it was off to the clink they went.
An hour later, the police returned to Fernandez's and Rojas' apartment. Rojas gave verbal and written consent to search the apartment. Then the four year old showed them where daddy kept his sawed-off shotgun. The police also found gang paraphernalia (related to the gang whose territory the robbery had occurred in), the clothes which were worn during the robbery, a butterfly knife, and some ammo. Fernandez was eventually convicted of crimes including the robbery, DV, possession of a firearm whilst a convicted felon, and other weapons crimes. He appealed his conviction, arguing that the evidence should have been suppressed.
Fernandez's argument is that the search of his property was impermissible under Randolph.
The Court gives a little background on two-party consent in its decision, citing a couple of older cases that I haven't summarized yet, so I'll go into them here. In US v. Matlock, Matlock was arrested in his front yard for a bank robbery. Once he was in the squad car, police asked Matlock's girlfriend for consent to search their room (rather than asking Matlock himself, which they could easily have done). The search yielded incriminating evidence, and the court found that the search was valid because Matlock's girlfriend had common authority with him over the premises and effects that the police searched.
In Illinois v. Rodriguez, a mad woman let the police into the apartment which she shared with Rodriguez (who was sleeping at the time), and they found drugs and paraphernalia. Then they found out that it wasn't really her apartment, she had already moved out and no longer had any authority over the premises. The court held that the search was reasonable anyway, because at the time of the search the police reasonably believed that it was her apartment.
And that brings us back to Randolph... most cops are pretty familiar with this one. Randolph's wife told police that he had cocaine in the house. Randolph told the cop he couldn't come in, so the cop simply turned to Randolph's wife and asked her for consent to search. The court eventually ruled that the refusal of a present party who objects to the search overrides the consent given by another party. The court made it explicitly clear that the objecting party must be present in order to have a say in it, unless the police removed him for the purpose of overcoming (or avoiding) his objection.
Now we're back to this case (and probably the most important paragraph of my summary). One of Fernandez's two arguments is that his objection to the search should have stood even though he wasn't present, since the only reason he wasn't present was that the police removed him. The Supreme Court ruled that this, like other Fourth Amendment inquiries, is not a question of the officers' subjective intentions. The question is whether it was objectively reasonable to remove the objecting party (and in cases like this one, where there's PC to arrest for DV, a violent robbery, or both, it's reasonable to do so). Randolph's prohibition against removing someone for the sake of overcoming their objection is only invoked if the police remove them without an objectively reasonable basis for doing so. And just like that, Randolph went from being a complicated problem to a minor footnote.
Fernandez's other argument is that because he objected to the search while he was present, his objection should have remained in effect until there was some sort of evidence that he had changed his mind. The Court didn't think much of that, though. For one thing, it creates more problems than it solves. The court gave a hypothetical example of someone serving a fifteen year sentence, and their co-tenant still being unable to give police consent to enter their house ten years into that sentence just because at one time someone who had lived there had objected to a search. The court also wondered if one could register in advance their objection to searches, or if they'd be putting the police in a position of having to determine whether or not the objecting party still has standing to object after being sentenced to the hypothetical fifteen year sentence. Or would the objection only last for a specif amount of time? How long? And the court wondered if such standing objections would attach to specific officers, to specific agencies, to specific investigations, to any officer who knew about them, or what.
More importantly than all of those ridiculous arguments, the Court felt that such standing objections to a search wouldn't really be in keeping with the spirit of the Randolph decision. Randolph was decided largely based on social norms... if your average person (like a domestic violence social worker, a friend, or a relative) were invited into a house by one resident while being simultaneously warned to stay out by another resident, then they probably wouldn't feel comfortable going in. If, on the other hand, the person warning them to stay out was removed (and they knew he wasn't going to come back during the visit), then the average person might feel more comfortable accepting the invitation. Besides, allowing Fernandez to simply create a standing objection to police entry that overrides Rojas' consent even after he leaves would show disrespect for her independence and give Fernandez power over her that the Fourth Amendment never intended.
Long story short, the court didn't agree with Fernandez's arguments. Rojas' consent to search the apartment was held to be valid, and the evidence found during the search was admissible against Fernandez. His conviction was upheld.