Illinois v. Gates

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Illinois v. Gates is a 1983 U.S. Supreme Court decision that established the "totality of the circumstances" test for determining whether an informant’s tip provides probable cause for issuing a search warrant.

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Predicate Object
instanceOf Fourth Amendment case
United States Supreme Court case
criminal procedure case
appliesTo federal criminal prosecutions
state criminal prosecutions
areaOfLaw criminal investigations
search and seizure
chiefJusticeAtDecision Warren E. Burger
citation Illinois v. Gates self-linksurface differs
surface form: Illinois v. Gates, 462 U.S. 213 (1983)
citationStyle 462 U.S. 213
constitutionalProvision Fourth Amendment to the United States Constitution
country United States of America
surface form: United States
court Supreme Court of the United States
decisionDate 1983-06-08
decisionType majority opinion
factPattern Police corroborated parts of the anonymous tip through surveillance before seeking a warrant.
Police received an anonymous letter alleging that Lance and Susan Gates were engaged in drug trafficking.
fullCaseName Illinois v. Gates self-link
holding The Fourth Amendment probable cause determination for issuing a search warrant is based on a totality of the circumstances test.
The rigid two-pronged Aguilar–Spinelli test is abandoned in favor of a more flexible totality of the circumstances approach.
impact Became the leading Supreme Court precedent on probable cause based on informant information.
Made it easier for law enforcement to use informant tips to obtain search warrants.
influenced later Supreme Court and lower court decisions on anonymous tips and probable cause
jurisdiction United States of America
surface form: United States
languageOfDecision English
legalIssue probable cause standard for search warrants
use of informant tips to establish probable cause
legalPrinciple probable cause is a fluid concept turning on the assessment of probabilities in particular factual contexts
majorityOpinionBy William H. Rehnquist
overruledDoctrine Aguilar–Spinelli test
page 213
precedentFor evaluation of informant reliability and basis of knowledge
probable cause determinations based on anonymous tips
reasoning A deficiency in one factor, such as an informant’s veracity, may be compensated for by a strong showing on another factor, such as basis of knowledge or corroboration.
Probable cause is a practical, common-sense decision based on all circumstances set forth in the affidavit.
relatedCase Aguilar v. Texas
Spinelli v. United States
reporter United States Reports
result The search warrant for the Gateses’ car and home was upheld as supported by probable cause.
standardAnnounced totality of the circumstances test for probable cause
stateParty Illinois
subjectMatter search warrant based on anonymous informant tip
subjectOf numerous criminal procedure casebooks and law review articles
volume 462
yearDecided 1983

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Illinois v. Gates citation Illinois v. Gates self-linksurface differs
this entity surface form: Illinois v. Gates, 462 U.S. 213 (1983)
Illinois v. Gates fullCaseName Illinois v. Gates self-link