Abandonment of the two-pronged test
Illinois v. Gates

Abandonment of the two-pronged test

In Illinois v. Gates (462 U.S. 213) (1983), the Supreme Court explicitly abandoned the two-pronged rule in favor of the totality of the circumstances rule. According to the opinion, written by Justice William Rehnquist:

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.^[8]

Illinois v. Gates, 462 U.S. 213 (1983), is an important Fourth Amendment case. It overturned the two-pronged test for probable cause as set in Spinelli v. United States with the "totality of circumstances" test. Illinois v. Gates established the "totality of circumstances" test in finding probable cause under the Fourth Amendment.

Summary of the facts

In May of 1978, the Bloomingdale, Illinois Police Department received an anonymous letter. The author of the letter claimed that Lance and Sue Gates were involved in an interstate drug trafficking ring, 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 350lbs. 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.

 U.S. Supreme Court ruling            

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 two-pronged test from Spinelli in favor of a "totality of circumstances" test. This case sees this new test applied. While the reliability and basis of knowledge of an anonymous tipster cannot be measured, when corroborated by the actions of the Gates, it satisfies the requirement to establish "probable cause."

Footnotes

1. ↑ Spinelli v. United States (393 U.S. 410)
2. ↑ Weeks v. United States (232 U.S. 383)
3. ↑ Mapp v. Ohio (367 U.S. 643)
4. ↑ Illinois v. Gates (462 U.S. 213, 238)
5. ↑ Johnson v. United States (333 U.S. 10)
6. ↑ Aguilar v. Texas (378 U.S. 108)
7. ↑ Spinelli v. United States (393 U.S. 410)
8. ↑ Illinois v. Gates (462 U.S. 213, 214)

References

• Copy of case via Findlaw
• 462 U.S. 213, 103 S.Ct. 2317, 76 L.Ed.2d 527 (1983).

http://en.wikipedia.org/wiki/Illinois_v._Gates