Illinois V. Gates - Facts and Procedural History

Facts and Procedural History

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.

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 Gateses' arrival home, the Bloomingdale Police searched the car, recovering over 350 lb. of marijuana. A search of the Gateses' 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.

The case was brought to the United States Supreme Court when the state and several amici curiae, friends of the court, asked them to review the decision. The main question that was presented was, “May a judge issue a search warrant on basis of partially corroborated anonymous informant’s tip?”