Illinois v. Gates

Illinois v. Gates

United States Supreme Court
462 U.S. 213 (1983)

ISSUE: Is an anonymous tip via a letter that does not include information about where the tipster acquired the information about his credibility still a sufficient basis for determining that there is probable cause to search Ds' house?
HOLDING: Yes, but only because the Aguilar-Spinelli test is deemed not useful.
FACTS:
  • Police received an anonymous letter that said that Sue and Lance Gates were engaged in drug trafficking where Sue would drive the car down to Florida where it would be loaded up with drugs, and then Lance would fly down and drive it back to Bloomingdale, Illinois where they lived
  • Police found that a driver's license had been issued to a Lance Gates with an address in Bloomingdale and than an L. Gates had bought an airplane ticket to West Palm Beach, FL
  • Gates boarded the flight, arrived in West Palm Beach, went to a room registered in the name of one Susan Gates, and then left in a car on the same interstate used by people traveling from FL to Chicago with a license plate on the car registered to the Gates
  • Upon executing search warrant, 350 lbs. of marijuana were found in the trunk of the car along with marijuana, weapons, and other contraband in the house
PROCEDURAL HISTORY:
  • Search warrant issued by circuit court judge
  • Illinois Supreme Court determined that the affidavit did not contain sufficient additional information to support a determination of probable cause after considering the letter
  • It thought that the letter had to satisfy both prongs of theAguilar-Spinelli test in order to be relied upon
RULES:
  • Spinelli: Only the probability, and not the prima facie showing, of criminal activity is the standard of probable cause
  • Standard for review of PC determination: So long as the magistrate has a "substantial basis" or concluding that a search would uncover evidence of wrongdoing, the 4th Amdt. requires no more
REASONING:
  • Two elements of Aguilar-Spinelli test are highly relevant in determining the value of the tip, but they are not separate and independent
  • Abandon two-prong Aguilar-Spinelli test
  • A totality-of-the-circumstances analysis is better in illuminate whether there is PC
    • PC deals with probabilities and is not technical
    • Rigid rules are not suited for tips
    • Even if there is some doubt as to an informant's motives, his explicit and detailed description of alleged wrongdoing along with a statement that the event was observed first-hand entitles his tip to greater weight
  • Rigorous technical specifications don't work because warrants are issued on a nontechnical, common-sense judgment of PC
  • Totality of the circumstances analysis: The issuing magistrate must make a practical, common-sense decision whether, given all the circumstances set forth in the affidavit before him, including the "veracity" and "basis for knowledge" of persons supplying hearsay information, there is a fair probability that contraband or evidence of a crime will be found in a particular place
    • Affidavit must provide the magistrate with a substantial basis for determining the existence of PC
  • PC in present case: Facts obtained through investigation alone suggested drug trafficking
    • Magistrate could rely on the anonymous letter too because if the tipster was right about some things, he is probably right about others
    • Corroboration through other sources provided a substantial basis for crediting the hearsay

 

Leave a Reply