Illinois v. Gates

In 1983, an Illinois Police department received an anonymous letter. This letter contained information that incriminated two members of the community, Lance and Susan Gates. It was alleged that this married couple was partaking in the illegal possession and sale of drugs. The letter stated that the wife would drive down to Florida and load her vehicle with the illegal substances. Then the husband would fly down to join her, and drive the car back to Illinois. The tip also included that there was over $100,000 of drugs in the couples home, and that they would be returning with over $100,000 of drugs in their car. The police, after receiving this information, looked into the validity of the accusations. They confirmed that many of the statements appeared to be true. The department noticed that the husband had booked a plane ticket to Florida, and had met his wife to drive back to Illinois. From the anonymous letter and the evidence that backed it up, the police were able to obtain a warrant to search the car and home of Lance and Susan Gates. When this warrant was used the police found 350 pounds of marijuana in their vehicle, and additional evidence of drug sale in their home.

However, an issue came up when this evidence was used in court. The Gates attorney argued that the evidence collected by the police department was inadmissible because the police lacked probable cause when the warrant was issued. The precedent for probable cause was set in Aguliar v. Texas and Spinelli v United States it is these two cases that created a standard for anonymous information. Two prongs must be met to qualify as probable cause. First, the informant must present the way in which they recieved the information. Second, there must be facts provided about the veracity of the informant. Unfortunately, the letter in this case failed to meet these prongs.

The case in the Supreme Court was decided 6-3 for Illinois. The reasoning for standing behind the police department was dependent on the evidence of the case. Though the letter did not pass the prongs test, it was corroborated by enough evidence to have indubitable evidence for a warrant. This is because the letter contained a variety of evidence that would have been difficult to obtain, as well as predicted the future actions of Lance and Susan gates. By taking this into consideration, a the judge who issued the warrant had a “substantial basis” for concluding that probable cause was present.
This case focuses on fourth amendment rights, and the procurement of evidence in a criminal case. I feel that an important aspect of this case, that will always apply to the legal system is something bigger. This case challenges the concept of precedent in judicial decision making. In order to come to this decision, the court had to take the cases of Aguliar and Spinelli into consideration. While those cases had established a standard of probable cause, this case challenged that standard. Illinois v Gates overturned prior decision, and set new precedent for future cases. The dispute of Stare decisis is going to be continuously important as times change, and the law changes as well.

Sources:

http://www.duanemorris.com/articles/urging_a_change_in_the_law_when_to_set_aside_precedent_5578.html?utm_source=Mondaq&utm_medium=syndication&utm_campaign=View-Original

https://supreme.justia.com/cases/federal/us/378/108/case.html

https://www.oyez.org/cases/1982/81-43

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