What is the test for a spouse co-habitant's Fourth Amendment claim against defendants?

Defendants argue that both of plaintiff's Fourth Amendment claims necessarily fail as a matter of law because his wife gave them consent to conduct the searches. Citing United States v. Matlock, 415 U.S. 164 (1974), defendants assert that plaintiff's wife had common authority over both premises because he was a spouse co-habitant. Defendants further cite United States v. Sealey, 830 F.2d 1028 (9th Cir. 1987), for the proposition that this remains true even though the spouses are adverse. According to defendants:

In his opposition and cross-motion, plaintiff argues that defendants are not entitled to summary judgment on any of his claims and that he is entitled to judgment as a matter of law as to his third claim relating to the search at space 23.³ As to space 23, plaintiff cites Georgia v. Randolph, 547 U.S. 103 (2006), for the proposition that "in circumstances like the ones in the present case, a physically present co-occupant's stated refusal to permit entry prevails, rendering the warrantless search unreasonable and invalid as to him."