The general rule under Pennsylvania law is that police officers must obtain a warrant prior to searching any area or item.  An exception to the general rule occurs when the owner of the place or item to be searched consents to the police officer searching without a warrant.  In those cases, the search is not unlawful if the consent was validly given.

In order to determine the validity of the consent, the courts focus is on the interaction between the police officer and the individual.  Where the interaction is lawful, the court deems the consent is valid.  Therefore the analysis is focused on what type of interaction occurred between the police officer and the individual and did the police officer possess the requisite level of suspicion to create that interaction.