Sunday, November 3, 2013

Spinelli v. United States case brief

Spinelli v. United States case brief summary
393 U.S. 410 (1969)

Defendant was convicted of traveling across the state line from Illinois to Missouri with the intention of conducting gambling activities proscribed by Missouri law. The United States Court of Appeals for the Eighth Circuit rejected his contention that the search warrant that led to incriminating evidence against him was not supported by probable cause and affirmed his conviction. The Court granted certiorari of that decision.

Defendant challenged the constitutionality of the warrant that authorized the Federal Bureau of Investigation (FBI) search, which uncovered the evidence necessary for his conviction. The warrant was granted by a magistrate judge upon an affidavit stating that the FBI had observed defendant's travels to and from an apartment and that a confidential reliable informant had informed the authorities that defendant was operating a gambling operation.

  • On certiorari, the court found that the application for the warrant was inadequate because it failed to set forth the underlying circumstances necessary to enable the magistrate to independently judge the validity of the informant's information. 
  • Also the affiant-officers failed to support their claim that their informant was "credible" or his information "reliable." 
  • The bald assertion that defendant was "known" as a gambler was entitled to no weight in appraising the magistrate's decision and the Court rejected as imprecise the "totality of circumstances" approach embraced by the court of appeals. 
  • Thus, the affidavit fell short of providing probable cause as necessary to support the issuance of the search warrant.


The Court reversed the judgment from the court of appeals, which affirmed the petitioner's conviction after finding the search warrant supported by probable cause. The court remanded the case to the court of appeals for further proceedings.

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

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