The rigid two-pronged Aguilar–Spinelli test is abandoned in favor of a more flexible totality of the circumstances approach.

E522190

This is the central holding of Illinois v. Gates, a landmark 1983 U.S. Supreme Court decision that reshaped the standard for evaluating probable cause based on informants’ tips under the Fourth Amendment.

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Statements (39)

Predicate Object
instanceOf U.S. Supreme Court decision ⓘ
affects evaluation of probable cause for search warrants ⓘ
police reliance on anonymous tips ⓘ
appliesTo informant information in warrant applications ⓘ
magistrates’ determinations of probable cause ⓘ
areaOfLaw criminal procedure ⓘ
search and seizure law ⓘ
changedFrom two-pronged Aguilar–Spinelli analysis ⓘ
changedTo holistic totality of the circumstances analysis ⓘ
characterizedAs leading case on informant-based probable cause ⓘ
citation 462 U.S. 213 ⓘ
citationStyle Illinois v. Gates, 462 U.S. 213 (1983) ⓘ
linked to: Illinois v. Gates
constitutionalProvision Fourth Amendment to the United States Constitution ⓘ
country United States ⓘ
court Supreme Court of the United States ⓘ
dateDecided 1983 ⓘ
decisionType landmark decision ⓘ
establishes totality of the circumstances test for evaluating probable cause based on informants’ tips ⓘ
holding The rigid two-pronged Aguilar–Spinelli test is abandoned in favor of a more flexible totality of the circumstances approach. ⓘ
impact lower courts generally apply totality of the circumstances rather than Aguilar–Spinelli for informant tips ⓘ
jurisdiction United States ⓘ
legalIssue probable cause ⓘ
use of informants’ tips ⓘ
legalPrinciple deficiencies in one factor may be compensated for by a strong showing of another factor under totality of the circumstances ⓘ
veracity, reliability, and basis of knowledge remain relevant but are not rigid requirements ⓘ
majorityOpinionBy William H. Rehnquist ⓘ
overrulesOrModifies Aguilar–Spinelli test ⓘ
party Lance Gates ⓘ
Susan Gates ⓘ
precedentFor later Fourth Amendment probable cause cases ⓘ
reasoning probable cause is a practical, nontechnical concept based on common-sense judgments ⓘ
rigid tests are inconsistent with the flexible nature of probable cause ⓘ
replacedStandard Aguilar–Spinelli two-pronged test ⓘ
result search warrant upheld under totality of the circumstances ⓘ
standardAnnounced totality of the circumstances ⓘ
stateParty Illinois ⓘ
subjectMatter use of an anonymous letter to establish probable cause ⓘ
topic anonymous informant tips ⓘ
standards for issuing search warrants ⓘ

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Illinois v. Gates → holding → The rigid two-pronged Aguilar–Spinelli test is abandoned in favor of a more flexible totality of the circumstances approach. ⓘ