Marriage and consent to search

Here's an interesting case, United States v. Buckner:

Frank Gary Buckner appeals from an order denying his motion to suppress evidence gathered from password-protected files on the hard drive of a computer police seized from his home. The officers seized and searched the computer, without a warrant, on the basis of oral consent granted by Buckner’s wife, Michelle. On appeal, Buckner contends that although Michelle’s consent sufficed to give the officers permission to search the computer itself, her consent could not extend to his password-protected files. Because Michelle Buckner did have apparent authority to consent to the search of these files, we affirm.

Nowhere in the court's analysis of the question whether Michelle Buckner had authority (actual or apparent) to consent does the question arise whether the fact that she is his wife supplies that authority.  That is, the court treats the case like any other third-party-consent case.  I wonder -- putting aside the in's and out's of Fourth Amendment doctrine -- what we should think of this.  What does the court's silence say, or teach, about marriage?