Can a party who has access to the premises give consent to a search?

In United States v. Dubrofsky, 581 F.2d 208 (9th Cir.1978), we held that "[a] party who has a key to the premises and access throughout the residence can also give a valid consent to search." Id. at 212. I would concede that, absent an express statement to the contrary, actions consistent with ownership or consensual mutual use of the property are sufficient to justify an officer's good faith belief that the third party had authority to consent to a search of the premises. Likewise in Matlock, mutual use of the premises without indications to the contrary was also sufficient to support a search.