3rd Party consent to search?

United States v. Arrington, 296 Fed. Appx. 646, No. 08-4018, unpublished op. (10th Cir. 14 October 2009).

The estranged wife of the accused had no actual or apparent authority to consent to a search of the accused's hotel room.  This was so even though the room was rented in the wife's mother's name and the wife paid for the room.

Because (1) she did not have mutual use of the property by virtue of
joint access since she spent a total of 20 minutes in the room with
defendant, did not have a key, did not leave any personal belongings in
the room, and did not plan to spend the night there, and (2) she did
not have control for most purposes over the property since the
presumption of control based on a husband-wife relationship was
rebutted because she and defendant were estranged, he stabbed himself
and threatened suicide, they did not have a close relationship, and he
requested that her name be removed from the room's guest registry.