Illinois V. Gates - Holding and Rationale

Holding and Rationale

The Supreme Court overturned the ruling of the Illinois courts. Justice William Rehnquist delivered the decision. In a 6–3 ruling, the prosecutors won the case. Justice Rehnquist stated:

We agree with the Illinois Supreme Court that an informant's "veracity," "reliability" and "basis of knowledge" are all highly relevant in determining the value of his report. We do not agree, however, that these elements should be understood as entirely separate and independent requirements to be rigidly exacted in every case hey should be understood simply as closely intertwined issues that may usefully illuminate the common sense, practical question whether there is "probable cause" to believe that contraband or evidence is located in a particular place.

This rejected the Aguilar–Spinelli test and put in place a totality-of-the-circumstances standard. This was put into place because the court recognized that there was more evidence that the Gateses were involved in drug trafficking than just the letter standing alone. The court agreed that if the letter had just stood alone it would not be probable cause to get a warrant. The court also recognized that under the Aguilar–Spinelli two-pronged test, it would be very hard for the “reliability” prong to ever be satisfied from an anonymous tip so it therefore should be abandoned.

This case is a landmark case in the evolution of probable cause and search warrants. In this case, the Supreme Court abandons the Aguilar–Spinelli test.