In what circumstances can a general consent to search result in intentional damage to a home?

Notably, I have found no federal case that holdsor suggestsotherwise. Although some cases have held that there are circumstances in which a general consent to search allows for intentional damage to personal property,² no appellate decision, as far as I can tell, has approved massive damage to a dwelling after a general consent to search. See also United States v. Ibarra , 965 F.2d 1354, 135758 (5th Cir. 1992) (en banc) (per curiam) (affirming by equally divided court with seven judges determining that the officers exceeded the scope of consent by using a sledgehammer to break boards securing entry to the attic).

[931 F.3d 991]