Illinois v. Gates
Supreme Court of United States (1983)

Defendant/Respondent:- Mr. & Mrs. Gates; Chicago police received an anonymous letter which stated that the defendants were involved in drug trade business. The letter clearly stated how the defendants went to Florida from Chicago to get drugs and how they came back to Chicago. The letter also gave the police the next date when the defendants were going to Florida to get drugs. The police detective who took over this case followed the actions of the defendants and everything written in the letter proved to be accurate. The detective made an affidavit based on the letter and his investigation and the judge issued the warrant. When the defendants reached their home back in Chicago, the officers searched their car and their house and found large amount of drugs and weapons. The Illinois Supreme Court suppressed the evidence by ruling that the Judge issued the warrant without probable cause beign established by the affidavit. The Supreme Court applied a strict two prong test to see if the informant's letter and the affidavit established probable cause and it ruled that these items did not establish probable cause, which is needed for a warrant to be issued.

Issue:- Was the warrant issued by the Judge invalid?

Holding:- No

Legal Reasoning:- The court ruled that a strict two prong test can not be used in a situation similar to the one in the current case. The court stated: "Informants' tips, like all other clues and evidence coming to a policeman on the scene may vary greatly in their value and reliability. Rigid legal rules are ill-suited to an area of such diversity." The court further stated that probable cause is a nontechnical concept which does not require the legal thinking of a legal scholars. The court ruled that even though the letter by itself did not establish probable cause, the investigation of the police detectives which confirmed every information given in the letter to be true, established probable cause, on the basis of which the warrant was issued. So the ruling of the lower court was reversed.

BACK