Illinois v. Gates

SCOTUSCase
Litigants=Illinois v. Gates
ArgueDate=October 10
ArgueYear=1982
ReargueDate=March 1
ReargueYear=1983
DecideDate=June 8
DecideYear=1983
FullName=Illinois v. Gates et ux.
USVol=462
USPage=213
Citation=
Prior=85 Ill. 2d 376, 423 N. E. 2d 887, reversed.
Subsequent=
Holding=Established the "totality of circumstances" test in finding probable cause under the Fourth Amendment.
SCOTUS=1981-1986
Majority=Rehnquist
JoinMajority=Burger, Blackman, Powell, O'Connor
Concurrence=White (in the judgement of the court only)
JoinConcurrence=
Concurrence2=
JoinConcurrence2=
Concurrence/Dissent=
JoinConcurrence/Dissent=
Dissent=Brennan
JoinDissent=Marshall
Dissent2=Stevens
JoinDissent2=Brennan
LawsApplied=

"Illinois v. Gates", ussc|462|213|1983, is a Fourth Amendment case. "Gates" overruled "Aguilar v. Texas", ussc|378|108|1964 and "Spinelli v. United States", ussc|393|410|1969, thereby replacing the Aguilar-Spinelli test for probable cause with the "totality of the circumstances" test.

Facts and Procedural History

In May 1978, the Bloomingdale, Illinois Police Department received an anonymous letter. The author of the letter claimed that Lance and Sue Gates were engaged in the interstate transportation and selling of narcotics, in which Sue Gates would drive a car to Florida, where it would be loaded with drugs. After the car had been loaded, Lance would fly to Florida and drive the car back to Illinois, where the drugs would be sold. Further, the author declared that the two currently had over $100,000 in drugs hidden in their basement. Finally the author implied that these two could potentially lead to the identification of larger scale dealers.

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.

Holding and Rationale

The Supreme Court overturned the ruling of the Illinois courts. As Justice William 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 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 Brennan, joined by Justice Marshall, stated that "Only one of the cases cited by the Court in support of its 'totality of the circumstances' approach, "Jaben v. United States", 381 U.S. 214 (1965), was decided subsequent to Aguilar. It is by no means inconsistent with "Aguilar"." [Id. at 286. (dissenting op.)] The dissent argued that the two pronged test of the honesty of the informant and the basis of knowledge was more protective of a citizen's rights, leaving less chance of a warrant being issued based upon the claims of a dishonest or unreliable "informant."

Additional Points

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" [meaning that it was not explicitly contested or argued in the state court, see "Gates" at 222.] and that the exclusionary rule had become too difficult as an issue of great public importance to have been re-examined at the time.

ee also

* List of United States Supreme Court cases, volume 462
* Aguilar-Spinelli Test

References

*caselaw source
case="Illinois v. Gates", 462 U.S. 213 (1983)
enfacto=http://www.enfacto.com/case/U.S./462/213/
findlaw=http://caselaw.lp.findlaw.com/scripts/getcase.pl?navby=case&court=us&vol=462&page=213

Notes