People v. Lyons 

Defendant was convicted, after bench trial, of possession of child pornography. Court properly denied Defendant's motion to suppress evidence of electronic media his wife gathered from their home and delivered to police. Wife made purely voluntary deliver of items (floppy disks and DVDs) to police, and did not abandon them. Proof that spouses have common authority over a space is rebuttable proof that each spouse has authority over containers within that space jointly owned or used by the spouses, and over containers owned or in practice used by one spouse alone. Wife and Defendant had common authority over cabinet given that both had right of access, as both had a key to cabinet, and thus both had common authority over the disks and DVDs inside, and Defendant gave no directives to wife that she could not access cabinet. (ZENOFF and HUDSON, concurring.)