What is the test for consent under the Fourth Amendment?

"It is ... well settled that one of the specifically established exceptions" to the Fourth Amendment requirements that private property not be searched without a search warrant issued upon probable cause "is a search that is conducted pursuant to consent." Schneckloth v. Bustamonte , 412 U.S. 218, 219, 93 S.Ct. 2041, 36 L.Ed.2d 854 (1973). When the " prosecut[ion] seeks to rely upon consent to justify the lawfulness of a search, [it]

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has the burden of proving that the consent was, in fact, freely and voluntarily given. " Id. at 222, 93 S.Ct. 2041 (quoting Bumper v. North Carolina , 391 U.S. 543, 548, 88 S.Ct. 1788, 20 L.Ed.2d 797 (1968) ).

The analysis required to determine whether consent to search was given freely and voluntarily, however, differs somewhat from the above Fifth Amendment analysis as to whether the postarrest right to remain silent was "knowingly" and voluntarily waived, for "[t]here is a vast difference between those [Fifth Amendment truth-seeking] rights that protect a fair criminal trial and the rights guaranteed under the Fourth Amendment." Schneckloth , 412 U.S. at 241, 93 S.Ct. 2041. Whereas "[a] strict standard of waiver has been applied to those [Fifth Amendment] rights guaranteed to a criminal defendant to insure that" he "has not unknowingly relinquished the basic protections ... thought indispensable to a fair trial," id. at 242, 93 S.Ct. 2041, the Fourth Amendment's focus is not on truth-seeking at trial but rather on "protect[ing] the security of one's privacy against arbitrary intrusion by the police, " id. (quoting Wolf v. Colorado , 338 U.S. 25, 27, 69 S.Ct. 1359, 93 L.Ed. 1782 (1949) ).