Illinois v. Gates
| Illinois v. Gates | |
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| Argued October 10, 1982 Reargued March 1, 1983 Decided June 8, 1983 |
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| Full case name | Illinois v. Gates et ux. |
| Citations | 462 U.S. 213 (more) |
| Prior history | 85 Ill. 2d 376, 423 N. E. 2d 887, reversed. |
| 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 | |
| Case opinions | |
| Majority | Rehnquist, joined by Burger, Blackmun, Powell, O'Connor |
| Concurrence | White (in the judgment of the court only) |
| Dissent | Brennan, joined by Marshall |
| Dissent | Stevens, joined by Brennan |
| Laws applied | |
| U.S. Const. amend. IV | |
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This case overturned a previous ruling or rulings
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Aguilar v. Texas (1964) Spinelli v. United States (1969) |
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Illinois v. Gates, 462 U.S. 213 (1983), is a Fourth Amendment case. Gates overruled Aguilar v. Texas, 378 U.S. 108 (1964) and Spinelli v. United States, 393 U.S. 410 (1969), thereby replacing the Aguilar–Spinelli test for probable cause with the "totality of the circumstances" test.
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, who 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 flies down and drives it back. Sue flies back after she drops the car off in Florida. May 3 she is driving down there again and 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 drug 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 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.
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