District of Columbia Court of Appeals
White v. United States
September 3, 2026
Summary
The Court affirmed the trial court’s denial of the motion to suppress GPS data, holding that the limited sharing of the defendant’s location with police was reasonable under the Fourth Amendment. It vacated the trial court’s denial of the defendant’s Section 23‑110 motion, finding error in the prejudice analysis and the determination that counsel’s performance was not deficient, and remanded for further proceedings. The decision rests on established Fourth Amendment privacy analysis and Strickland/Frye standards for ineffective assistance of counsel.