What is the test for consent under the Fourth Amendment?

As "[t]he touchstone of the Fourth Amendment is reasonableness," Florida v. Jimeno , 500 U.S. 248, 250, 111 S.Ct. 1801, 114 L.Ed.2d 297 (1991), "[t]he standard for measuring the scope of a suspect's consent under the Fourth Amendment is that of objective reasonableness-what would the typical reasonable

[926 F.3d 77]

person have understood by the exchange between the officer and the suspect?" Id. at 251, 111 S.Ct. 1801. Thus, "the ultimate question presented is whether the officer had a reasonable basis for believing that there had been consent to the search." United States v. Garcia , 56 F.3d 418, 423 (2d Cir. 1995) (internal quotation marks omitted).