What is the test for obtaining general consent to search a locked metal box?

The court in United States v. Jones (4th Cir. 2004) 356 F.3d 529 (Jones) held that, where a police officer was given permission to search a suspect's duffle bag, it was objectively reasonable for the officer to search a locked metal box contained in the bag.⁶ (Id. at pp. 532, 534-535.) The court first noted that, when an officer receives a general consent to search a particular area, the officer "does not need to return to ask for fresh consent to search a closed container located within that area." (Id. at p. 534 [noting that the object of the search was "illicit drugs"].) The court then considered the suspect's claim that "locked containers are different from closed containers and do not fall within the scope of a suspect's general consent to search a larger area." (Id. at p. 534.) Because the court's analysis of this question is instructive, and similar to the type of multi-factored approach we adopt here, we quote the court's reasoning at length:

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