Sunday, November 3, 2013

Illinois v. Gates case brief

Illinois v. Gates case brief summary
462 U.S. 213 (1983)

Petitioner state appealed a judgment from the Illinois Supreme Court, which affirmed the decisions of lower state courts granting a motion to suppress evidence against respondents, a husband and wife, as having been obtained pursuant to a search warrant improperly issued on the basis of a confidential informant's tip in violation of the Fourth Amendment.

A state supreme court ruled to suppress evidence against respondents, a husband and wife, reasoning that the search warrant was based on a confidential informant's tip that did not satisfy the purported "veracity" and "basis of knowledge" prongs for probable cause.

  • Holding instead that probable cause was determined by a traditional totality-of-the-circumstances analysis, the Court reversed. 
  • The Court held that probable cause determinations were not susceptible to the rigid, technical methodology that had been read into Fourth Amendment jurisprudence. 
  • The Court also held that the elements of an informant's veracity and knowledge should be understood simply as issues that could illuminate the commonsense inquiry of whether there was probable cause to issue a search warrant. 
  • The Court stated that this approach comported with the standard of proof for a warrant, which required only the "probability," and not a prima facie showing, of criminal activity. 
  • The Court further stated that the informant's recitation of detailed facts, though relating to innocent activities, when corroborated by observation by police officers, afforded probable cause to believe that respondents had drugs in their possession.


The Court reversed the judgment that suppressed evidence against respondents, a husband and wife, because the suppression was based on an erroneous application of an overly rigid and technical standard for determining whether a confidential informant's tip established probable cause; under the proper, commonsense approach, the corroboration by police of the facts of the tip established probable cause to believe that respondents possessed drugs.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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