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on previously-obtained, undisclosed consent of co-occupant without also requesting consent from defendant). Saadatdar v. State, 277 Ga.App. 339, 626 S.E.2d 552 (January 24, 2006). Trial court could conclude that defendant’s consent to enter his home was voluntary. Acting on a tip that defendant possessed an assault weapon, officers knocked on his door in the early morning hours. Defendant denied possessing such a weapon. “During the five minute conversation, officers asked to enter the residence ‘two or three times.’ Each time Saadatdar refused consent to enter. After some continued conversation, Saadatdar admitted that he once possessed an assault weapon. Following this admission, one of the officers commented: ‘Hey, people are looking at us. Your neighbors are looking at us. Do you want to let us in?’ Saadatdar then allowed the officers to enter his home on the condition that they could not conduct a search.” Once inside, officers saw evidence of drug use in plain view. “The fact that [officers] requested permission to enter the home several times and warned Saadatdar that his neighbors might see them at his door does not automatically render Saadatdar’s consent involuntary.” Smithson v. State, 275 Ga.App. 591, 621 S.E.2d 783 (September 23, 2005). Officer made an illegal warrantless entry into defendant’s home when he entered undercover as a contractor, “even though his sole purpose for the entry was to search for evidence of a crime.” “‘Consent which is the product of coercion or deceit on the part of the police is invalid.’ (Citation, punctuation and footnote omitted.) State v. Jourdan, 264 Ga.App. 118, 121(1), 589 S.E.2d 682 (2003).” Todd v. State, 275 Ga.App. 459, 620 S.E.2d 666 (September 9, 2005). Defendant had no standing to object to search of friend’s mobile home, where he was only there visiting. “‘The burden is on the one claiming a violation of Fourth Amendment rights to demonstrate that he has standing to contest such violation, i.e., that he has a legitimate expectation of privacy in the premises searched.’ (Punctuation and citations omitted.) Atwater v. State, 233 Ga.App. 339, 340(2) (503 S.E.2d 919) (1998). See also Brown v. State, 240 Ga.App. 321, 322(1) (523 S.E.2d 333) (1999). Todd has conceded on appeal that the mobile home was owned by a friend. Furthermore, Todd failed to come forward with any evidence that would suggest that he otherwise had a legitimate expectation of privacy in the mobile home.” Muehler v. Mena, 544 U.S. 93, 125 S.Ct. 1465, 161 L.Ed.2d 299 (March 22, 2005). Mena filed 1983 action against police officers, contending her detention in handcuffs while officers search her house, and questioning about her immigration status violated her Fourth Amendment rights. Ninth Circuit upheld jury award in her favor; Supreme Court vacates and remands, finding that “the officers’ detention of Mena in handcuffs during the execution of the search warrant was reasonable and did not violate the Fourth Amendment. Additionally, the officers’ questioning of Mena did not constitute an independent Fourth Amendment violation.” 1. Detention in handcuffs: “In Michigan v. Summers, 452 U.S. 692, 101 S.Ct. 2587, 69 L.Ed.2d 340 (1981), we held that officers executing a search warrant for contraband have the authority ‘to detain the occupants of the premises while a proper search is conducted.’ Id., at 705, 101 S.Ct. 2587. Such detentions are appropriate, we explained, because the character of the additional intrusion caused by detention is slight and because the justifications for detention are substantial. Id., at 701-705, 101 S.Ct. 2587. We made clear that the detention of an occupant is ‘surely less intrusive than the search itself,’ and the presence of a warrant assures that a neutral magistrate has determined that probable cause exists to search the home. Id., at 701, 101 S.Ct. 2587. Against this incremental intrusion, we posited three legitimate law enforcement interests that provide substantial justification for detaining an occupant: ‘preventing flight in the event that incriminating evidence is found’; ‘minimizing the risk of harm to the officers’; and facilitating ‘the orderly completion of the search,’ as detainees’ ‘self-interest may induce them to open locked doors or locked containers to avoid the use of force.’ Id., at 702-703, 101 S.Ct. 2587. Mena’s detention was, under Summers, plainly permissible. [Cit.] An officer’s authority to detain incident to a search is categorical; it does not depend on the ‘quantum of proof justifying detention or the extent of the intrusion to be imposed by the seizure.’ Id., at 705, n. 19, 101 S.Ct. 2587. Thus, Mena’s detention for the duration of the search was reasonable under Summers because a warrant existed to search 1363 Patricia Avenue and she was an occupant of that address at the time of the search. Inherent in Summers’ authorization to detain an occupant of the place to be searched is the authority to use reasonable force to effectuate the detention. See Graham v. Connor, 490 U.S. 386, 396, 109 S.Ct. 1865, 104 L.Ed.2d 443 (1989) (‘Fourth Amendment jurisprudence has long recognized that the right to make an arrest or investigatory stop necessarily carries with it the right to use some degree of physical coercion or threat thereof to effect it’).” Three factors identified as making detention in handcuffs appropriate here: search was “for weapons and a wanted gang member resides on the premises,” making in an “inherently dangerous situation[ ];” and “the need to detain multiple occupants.” Four justices concur in judgment only on this point. 2. Questioning about immigration status: “We have ‘held repeatedly that mere police questioning does not constitute a seizure.’ Florida v. Bostick, 501 U.S. 429, 434, 111 S.Ct. 2382, 115 L.Ed.2d 389 (1991); see also INS v. Delgado, 466 U.S. 210, 212, 104 S.Ct. 1758, 80 L.Ed.2d 247 (1984)…. As the Court of Appeals did not hold that the detention was prolonged by the questioning, there was no additional seizure within the meaning of