Illinois v. Gates, 462 U.S. 213 (1983)

Facts

The Bloomingdale police received an anonymous letter that the Gates sold narcotics and made trips to Florida to bring back narcotics.  Mader followed up on the tip and discovered that Lance had made a reservation to West Palm Beach.  Lance was followed to the hotel, where he left with Sue in the family car back to Bloomingdale.  A search warrant was issued based on the facts.  350 pounds of marijuana were discovered in the car.  Marijuana, weapons, and contraband were discovered in the house.

Procedural History

The Circuit Court ordered suppression of the evidence on the grounds that the affidavit failed to support the determination of probable cause.  The Court of Appeals and the Supreme Court affirmed.

Issue(s)

Did the lower courts err in suppressing the evidence on the grounds that Mader’s affidavit failed to support the determination of probable cause?

Holding(s)

Yes.

Reasoning/Analysis

The Court found that the Illinois court’s use of the two-prong test for determining probable cause was an incorrect understanding of probable cause.  The totality of the circumstances approach is far more consistent with our prior treatment of probable cause than is any rigid demand that specific tests be satisfied.  Probable cause is a fluid concept; one simple rule will not cover every situation.  The facts surrounding Lance’s trip are suggestive of a prearranged drug run.  As to the anonymous letter, along with Mader’s investigation, the judge had a substantial basis for concluding that probable cause existed.

Judgment/Outcome

The Court reversed the judgment of the lower courts.

Concurring Opinions/Dissenting Opinions/Comments

Brennan dissented stating that the majority provided no persuasive reason to abandon Aguilar and Spinelli.  Stevens also dissented stating that based on what the judge knew at the time of issuing the warrant, probable cause did not exist.