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Illinois V Gates

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In May 1978, the Bloomingdale, Illinois Police Department received an anonymous letter. The letter stated, "This letter is to inform you that you have a couple in your town who live on Greenway, off Bloomingdale Rd. in the condominiums. Most of their buys are done in Florida. Sue, his wife, drives their car to Florida, where she leaves it to be loaded up with drugs, then Lance flies down and drives it back. Sue flies back after she drops the car off in Florida. May 3 she is driving down there again and the car back he has the trunk loaded with over $100,000.00 in drugs. Presently they have over $100,000.00 worth of drugs in their basement. They brag about the fact they never have to work, and make their entire living on pushers. I guarantee, if you watch them carefully you will make a big catch. They are friends with some big drug dealers who visit their house often."

Detective Mader decided to follow up on the tip, obtaining further information that an "L. Gates" had purchased an airline ticket leaving from Chicago's O'Hare Airport and arriving in West Palm Beach, Florida. Working with the DEA, Mader was able to ascertain that Gates had boarded the plane and arrived in West Palm Beach. The DEA surveillance team determined that Gates had met a woman at a Holiday Inn room registered to Susan Gates and that the couple had gotten into a car together driving toward the Chicago area. They estimated the pair due back in Bloomingdale within 22 to 24 hours.

Mader signed an affidavit laying down the events as they had unfolded, in addition to the anonymous letter. A judge of the Circuit Court of DuPage County issued a warrant. Upon the Gates' arrival home, the Bloomingdale Police searched the car, recovering over 350 lb. of marijuana. A search of the Gates' residence led to the discovery of additional marijuana and weapons.

The Illinois Circuit Court decided that the search was unlawful based on the test established in the Supreme Court ruling in Spinelli v. United States. In essence, the affidavit did not provide enough evidence to establish probable cause, which led to the exclusion of evidence obtained on the basis of that warrant. This ruling was upheld by both the Illinois Appellate Courts and the Supreme Court of Illinois.

The case was brought to the United States Supreme Court when the state and several amicus curiae, friends of the court, asked them to review the decision. The main question that was presented was, "May a judge issue a search warrant on basis of partially corroborated anonymous informant's tip?"

[edit] Holding and rationale

The Supreme Court overturned the ruling of the Illinois courts. Justice William Rehnquist delivered the decision. In a 6-3 ruling, Illinois won the case. Justice Rehnquist stated:

We agree with the Illinois Supreme Court that an informant's "veracity," "reliability" and "basis of knowledge" are all highly relevant in determining the value of his report. We do not agree, however, that these elements should be understood as entirely separate and independent requirements to be rigidly exacted in every case[...] [T]hey should be understood simply as closely intertwined issues that may usefully illuminate the common sense, practical question whether there is "probable cause" to believe that contraband or evidence is located in a particular place.

This rejected the Aguilar-Spinelli test and put in place a totality-of-the-circumstances standard. This was put into place because the court recognized that there was more evidence that the Gateses were involved in drug trafficking than just the letter standing alone. The court agreed that if the letter had just stood alone it would not be probable cause to get a warrant. The court also recognized that under the Aguilar-Spinelli two-pronged test, it would be very hard for the "reliability" prong to ever be satisfied from an anonymous tip so it therefore should be abandoned.

This case is a landmark case in the evolution of probable cause and search warrants. In this case, the Supreme Court abandons the Aguilar-Spinelli



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