How has consent been interpreted in the context of a search warrant application?

( People v. James (1977) 19 Cal.3d 99, 106, 137 Cal.Rptr. 447, 561 P.2d 1135.) However, "where ... the prosecution relies on consent to justify a warrantless search or seizure, it bears the burden of proving that the defendant's manifestation of consent is a product of his free will and not a mere submission to a claim of lawful authority. " ( People v. Zamudio (2008) 43 Cal.4th 327, 341, 75 Cal.Rptr.3d 289, 181 P.3d 105 ; Bumper v. North Carolina (1968) 391 U.S. 543, 548, 88 S.Ct. 1788, 20 L.Ed.2d 797 [coercion exists when officer misrepresented that he has a valid warrant and occupant consents to the search].)