Illinois v. Gates
Illinois v. Gates | |
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Holding | |
The rigid "two-pronged test" under Aguilar and Spinelli for determining whether an informant's tip establishes probable cause for issuance of a warrant is abandoned, and the "totality of the circumstances" approach that traditionally has informed probable cause determinations is substituted in its place. | |
Court membership | |
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Case opinions | |
Majority | Rehnquist, joined by Burger, Blackmun, Powell, O'Connor |
Concurrence | White (in judgment) |
Dissent | Brennan, joined by Marshall |
Dissent | Stevens, joined by Brennan |
Laws applied | |
Spinelli v. United States (1969) |
Illinois v. Gates, 462 U.S. 213 (1983), is a
Facts and procedural history
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 strictly make their living on selling drugs. They are Sue and Lance Gates, they 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 flys down and drives it back. Sue flys back after she drops the car off in Florida. May 3 she is driving down there again and Lance will be flying down in a few days to drive it back. At the time Lance drives 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 drugs 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
Mader signed an affidavit laying down the events as they had unfolded, in addition to the anonymous letter. A judge of the
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 amici 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?"
Holding
The Supreme Court overturned the ruling of the Illinois courts. Justice William Rehnquist delivered the decision in favor of the State of Illinois. 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 test.
Dissent
In dissent, Justice
Concurring
Justice White concurred in the judgment. He wrote that in this case, the search and seizure was consistent with the Fourth Amendment. He stated that it was reasonable for the search of the Gateses' house. He stated that the exclusion of the evidence would have set the criminals free and it would not have served "any constitutional interest in securing compliance with the important requirements of the Fourth Amendment." Justice White does not believe that the exclusionary rule should be used in any case where law enforcement officials reasonably believe their actions are consistent with the Fourth Amendment.
Additional points
In Illinois v. Gates, probable cause was achieved for the warrant under the new "totality-of-the-circumstances" standard because the investigation by DEA and Detective Mader would have, on its own, been probable cause for a search warrant.[citation needed] The Gateses' actions were suspicious because Florida is a known source of illegal drugs. Lance Gates' stay at a motel for one night and immediate return to Chicago suggests that he was not going for a vacation and also implies that he might be involved in something illegal. The Court, after having heard oral argument, furthermore requested in November 1982 that the parties and amici submit briefs on the broader issue of whether the exclusionary rule should be modified. When the opinion in Gates was rendered, however, the Court declined to rule on the issue, stating that the issue was "not pressed or passed upon below"[5] and that the exclusionary rule had become too difficult as an issue of great public importance to have been re-examined at the time.
See also
References
- Epstein, Lee. "Illinois v. Gates." Constitutional Law for a Changing America.Third Ed. p. 490.1998.
External links
- Text of Illinois v. Gates, 462 U.S. 213 (1983) is available from: Cornell Findlaw Justia Library of Congress Oyez (oral argument audio)