US v. Coleman: Coleman lived with his girlfriend. One night, as he came home, he asked her to open the garage door for him. Unbeknownst to either, two men had earlier broken into the house and hid away in the garage. When Coleman's girlfriend went to open the garage door, she was attacked. In the struggle that ensued, Coleman was shot. After his girlfriend returned from next door (where she had called 911), Coleman retrieved a pistol from their bedroom and checked to make sure the attackers, who had fled, were out of the house. Coleman gave the gun to his girlfriend, telling her to "put it up" and had his brother take him to the hospital. The girlfriend stashed the gun under the mattress in their bedroom. When police arrived (after Coleman was taken to hospital), the obtained a consent to search the "anywhere in the house" from the girlfriend. Officers followed a trail of blood to the bedroom, searched under the mattress, and recovered the gun.
Coleman was charged with being a felon in possession of a firearm. He filed a motion to suppress the firearm, which the district court granted. The district court concluded that the search under the mattress exceeded the scope of the girlfriend's consent and emphasized that the gun, after investigation, turned out not to have been used by the attackers. On appeal, the Fourth Circuit unanimously reversed. Noting that there was no suggesting that the consent to search was given involuntarily, the court concluded that the search did not exceed the scope of that consent. The consent to search was exceptionally broad and had not been limited verbally by the girlfriend, who told police they could search "anywhere in the house." Furthermore, when officers found the blood trial that led to the bedroom and the discovery of the gun they could not know it was unrelated to the break in they were called to investigate.