Illinois v. Gates:   
United States Supreme Court, 1983. 

Statement of the Case:

      State is prosecuting the Gates for drug violations when they found out about the illicit activities and detailed plans through an anonymous source, and found drugs and weapons in the family’s house.

Procedure:

      The Illinois Circuit court suppressed the evidence, holding that there was no probable cause supported by the police affidavits. The Illinois Supreme Court affirmed, concluding that the letter did not pass the Spinelli-Aguilar two prong test.

Facts:

• The police received an anonymous letter stating that the Gates' (D) made their living by trafficking in drugs. The letter set forth a plan of how they obtained the drugs and gave dates for the next purchase, and that the informant knew because they bragged about it.
• The letter indicated that D had $100,000 worth of drugs stored in their house. The police were able to confirm that D's activities were as predicted in the letter, i.e., the wife drove her car to Florida and checked into a room and that the husband had reservations to fly to Florida. Police surveillance confirmed that the couple and car headed north the day after the husband arrived in Florida.
• Based on this information, a search warrant was issued. The car search revealed marijuana, and the search of D's house revealed drugs, weapons, and other contraband.

Issue:

      Whether an anonymous letter alleging criminal activity with detailed plans to complete this crime is sufficient to establish probable cause under the 4^th Amendment when it is coupled with a policeman's affidavits confirming activity conforming to the plan and the letter stated that the information was acquired based on the ?s bragging about their criminal activities.

Procedural Result:

      Judgment reversed for State.

Holding:

      Overruling the Aguilar-Spinelli Test, and looking to a “Totality of the Circumstances” Test, an anonymous letter alleging criminal activity with detailed plans to complete this crime is sufficient to establish probable cause under the 4^th Amendment when it is coupled with a policeman's affidavits confirming activity conforming to the plan and the letter stated that the information was acquired based on the ?s bragging about their criminal activities.

Reasoning:

• An informant's veracity, reliability, and basis of knowledge are all highly relevant in determining the value of his tip.
• Those elements are intertwined issues that may illuminate the common sense, but there is still the practical question of whether there is probable cause.
• A “Totality of the Circumstances” Test should be used, rather than a rigid, excessively technical, two prong analysis.
  • This is because probable cause is a fluid concept, and not readily reduced to a rigid set of rules.
  • It allows a balanced assessment of the relative weights of all the various indicia of reliability attending an informant's tip.
  • Very strong evidence as to one prong can make up for the weakness on the other prong, so they simply look at the totality and from all that info the magistrate can decide whether or not this informant has provided reasonably trustworthy information.
  • The detail in the letter seemed to suggest first hand knowledge.

CONCURRENCE: (White, J.)

      Since the warrant in this case would be upheld by the two prong test, there is no reason to reject the rule of Spinelli.

DISSENT: (Brennan, J.)

      The Spinelli test should not be rejected. It downgrades the neutral role of magistrates in the probable cause determination.

DISSENT: (Stevens, J.)

      The letter erred in predicting some facts of the crime, so it was not reasonable to rely on the letter as the basis for searching the home. The activity that was correctly predicted was innocent.

Additional Points: 

• Maryland v. Pringle:  Whether there was probable cause to arrest a passenger in a car when there was probable cause to believe that a felony narcotics violation had been committed by someone in the vehicle.
  • Yes, there was probable cause to arrest a passenger in a car when there was probable cause to believe that a felony narcotics violation had been committed by someone in the vehicle.
  • It was an “entirely reasonable inference” to find that any or all three riders knew of and exercised control over the cocaine.

• State Courts still may apply the Aguilar-Spinelli Test since they are free to interpret their State’s version of the 4^th Amendment however they want.