In re J.F.S., 300 A.3d 748

In January 2020 Andy Bonilla was shot and killed; surveillance and GPS tied a stolen Honda Accord to the scene. J.F.S., then 15, had purchased the stolen car and rode in it with three friends.
About an hour before the shooting, J.F.S. texted he was “looking for da opps” with multiple guns; four minutes before the shooting he recorded a video showing a gun in his lap.
Police later encountered J.F.S. at his home. His mother, S.S., who had bought the phone and whose name was on the account (and who had disconnected service), ordered him to give it up; he initially refused but later handed it to her and she gave it to officers.
Detectives obtained a warrant (supported by a detailed 21-page affidavit) to search the phone. The search produced texts and a video linking J.F.S. to the murder.
The trial court denied suppression motions (seizure and later Burns-based particularity challenge) and, after a bench trial, convicted J.F.S. of aiding and abetting first-degree murder. He appealed on Fourth Amendment and sufficiency-of-the-evidence grounds.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether mother had authority to consent to seizure of phone	Mother lacked authority; J.F.S.’s refusal and parents didn’t have passcode show no apparent authority	Mother bought phone, account in her name, she had confiscated it previously and asked police to take it	Apparent authority existed; officers reasonably believed mother could surrender the phone
Whether warrant was overbroad / insufficiently particularized	Warrant allowed broad electronic rummaging akin to Burns; insufficiently tailored to items/timeframe	Warrant backed by detailed affidavit showing likely locations/types of evidence; officers reasonably relied on it	Good-faith exception applied; officers could reasonably rely on the warrant (Abney analog)
Whether evidence sufficed to prove aiding and abetting first-degree murder	Evidence did not prove premeditated intent or active participation	Texts, video of gun, knowledge of plan, purchase of stolen car, and continued participation show intent and participation	Evidence sufficient to support aiding-and-abetting first-degree murder conviction

Illinois v. Rodriguez, 497 U.S. 177 (officer’s reasonable belief determines apparent third-party consent)
United States v. Matlock, 415 U.S. 164 (third-party consent doctrine; joint access/control)
United States v. Leon, 468 U.S. 897 (good-faith exception to exclusionary rule)
Burns v. United States, 235 A.3d 758 (D.C. 2020) (cell-phone warrants found overbroad and insufficiently particular)
Abney v. United States, 273 A.3d 852 (D.C. 2022) (officers reasonably relied on pre-Burns warrants; good-faith reliance)
Ashby v. United States, 199 A.3d 634 (D.C. 2019) (principles on third-party consent to searches)