Petitioner
State of Illinois
Respondent
Lance Gates
Petitioner's Claim
That evidence obtained via a search warrant that was later declared invalid could still convict.
Chief Lawyer for Petitioner
Paul J. Biebel, Jr., Assistant Attorney General of Illinois
Chief Lawyer for Respondent
James W. Reilley
Justices for the Court
Harry A. Blackmun, Warren E. Burger, Sandra Day O'Connor, Lewis F. Powell, Jr., William H. Rehnquist (writing for the Court), John Paul Stevens, Byron R.White
Justices Dissenting
William J. Brennan, Jr., Thurgood Marshall
Place
Washington, D.C.
Date of Decision
8 June 1983
Decision
Reversed the Illinois Supreme Court's decision that prevented evidence seizedfrom being presented at a criminal trial.
Significance
Provided law-enforcement authorities and prosecutors with a new and less restrictive set of rules to abide by in obtaining search warrants.
Under the Fourth Amendment to the United States Constitution, citizens are guaranteed certain rights regarding criminal prosecution. The Amendment states,in full, that
The Exclusionary Rule
Law-enforcement authorities need a valid warrant, or, in legal terms, a judicial writ, to search a citizen's home or person. Such guarantees, enshrined bythe Constitution, are considered cornerstones of a free, non-totalitarian society. In some instances, searches and seizures do occur without a proper writ, or have been granted under spurious grounds by judges, but any evidence obtained with such invalid warrants is not admissible in a trial. This is called the "exclusionary rule," for it excludes any evidence of a crime from beingpresented by prosecutors, no matter how damaging.
In May of 1978, a letter arrived at the police department of Bloomingdale, Illinois. The anonymous writer alleged that Bloomingdale residents Lance and Sue Gates were selling drugs from their home. The letter also provided a date on which the couple would travel to and return from Florida separately in order to ferry another shipment of contraband to their home for resale. Police investigated the Gates and their whereabouts, and confirmed that Lance Gates had flown to Florida and stayed in a motel room registered to his wife. Furtherinquiries revealed that Gates and an unidentified woman left the motel in acar with license plates registered to Gates, but for a different vehicle. With these details, Bloomingdale police obtained a warrant to search both the Gates residence as well as the car upon its arrival. They found 350 pounds of marijuana in the trunk of the car, and inside the house, more drugs and an unregistered firearm.
Invalid Warrant
Prior to Gates's trial, the respondents filed a motion to suppress the evidence, asserting the warrant that procured it had been obtained without "just cause." In legal terms, an anonymous tip is considered insufficient evidence for granting a search warrant. They were successful in this, and an appellate court upheld this decision suppressing all evidence. The Illinois Supreme Court also upheld the exclusion of evidence. All of these courts used two legal precedents in determining that the Bloomingdale police's search warrant was not valid. In the first, Aguilar v. Texas (1964), the courts had ruled that an informant's tip is enough to obtain a warrant if the police can determine the reliability of the source of this knowledge (for example, that the informant was a firsthand witness to it), and if the police can prove the informant's veracity in other areas. The Bloomingdale police's affidavit had neither.
Spinelli v. United States (1969), was another case used by courts to determine if a warrant was valid if it had not passed the requirements set forth in Aguilar v. Texas. Spinelli holds that there is "probablecause" to grant a warrant if some details provided by the tip are corroborated by police investigation, but if the informant presents evidence that may just be hearsay or rumor, this is not considered trustworthy. This was also a significant factor in barring evidence seized at the Gates home from incriminating them at their trial.
Hints of New Stance on Exclusionary Rule
The U.S. Supreme Court had ruled consistently in matters concerning the exclusionary rule since 1914. Again and again, it confirmed that evidence obtainedoutside proper legal means could not be used in a criminal trial. Yet by theearly 1980s, some conservatives had argued for exceptions to this rule. President Ronald Reagan asserted that the American people had lost faith in the legal system, viewing it as constrained by constitutional loopholes and unableto protect citizens from crime. He urged the granting of greater powers to law enforcement authorities to fight crime.
The State of Illinois asked the High Court to allow the drugs seized to be presented as evidence under a "good-faith" exception to the exclusionary rule.This exception took into account that the officers had acted in "good faith"that a crime had been committed; in other words, they believed they were operating within the law. Liberals, on the other hand, argued that granting a "good-faith" exception to the exclusionary rule would invent two separate realmsof the Constitution: one for citizens, who must abide by it, and another forlaw-enforcement authorities and the state, who were allowed to defy it. In other words, to adopt a good-faith exception to the exclusionary rule would endorse unconstitutional police behavior.
Decision, "With Apologies"
When Illinois v. Gates first appeared before the Supreme Court in October of 1982, the state of Illinois had requested that the High Court decide whether "probable cause" was present in the police affidavit that requested the warrant. The Illinois assistant attorney general later requested to enlargethe question to include whether or not such evidence was admissible in court, based on the "reasonable belief" that the search was valid under the FourthAmendment--even though it was later found not to be. After a few weeks, theSupreme Court motioned to return Illinois v. Gates to the docket, andit was re-argued in March of 1983.
On June 8 of that year, the Court issued its decision, with apologies. The good-faith clause had not been present in petitions to the lower courts,and the Supreme Court's task was to review the cases as they existed. It did, however, reverse the Illinois Supreme Court ruling barring the evidence against the Gates from trial. Justice Rehnquist's majority decision rejected theAguilar and Spinelli tests, and asserted that courts should abide by a "totality of circumstances" rule. This holds that a magistrate, presented with a police affidavit and request for warrant, should consider whether or not thereis a "fair probability" that evidence of a crime will be found at a specificplace, and found that the issuing judge and Bloomingdale police had acted within these precepts. Rehnquist also promised to look into modifying the exclusionary rule in three cases scheduled for the following term. Justices Brennan and Marshall dissented from the majority.
Related Cases
State of Illinois
Respondent
Lance Gates
Petitioner's Claim
That evidence obtained via a search warrant that was later declared invalid could still convict.
Chief Lawyer for Petitioner
Paul J. Biebel, Jr., Assistant Attorney General of Illinois
Chief Lawyer for Respondent
James W. Reilley
Justices for the Court
Harry A. Blackmun, Warren E. Burger, Sandra Day O'Connor, Lewis F. Powell, Jr., William H. Rehnquist (writing for the Court), John Paul Stevens, Byron R.White
Justices Dissenting
William J. Brennan, Jr., Thurgood Marshall
Place
Washington, D.C.
Date of Decision
8 June 1983
Decision
Reversed the Illinois Supreme Court's decision that prevented evidence seizedfrom being presented at a criminal trial.
Significance
Provided law-enforcement authorities and prosecutors with a new and less restrictive set of rules to abide by in obtaining search warrants.
Under the Fourth Amendment to the United States Constitution, citizens are guaranteed certain rights regarding criminal prosecution. The Amendment states,in full, that
The right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures,shall not be violated, and no warrants shall issue, but upon probable cause,supported by Oath of affirmation, and particularly describing the place to besearched, and the persons or things to be seized.
The Exclusionary Rule
Law-enforcement authorities need a valid warrant, or, in legal terms, a judicial writ, to search a citizen's home or person. Such guarantees, enshrined bythe Constitution, are considered cornerstones of a free, non-totalitarian society. In some instances, searches and seizures do occur without a proper writ, or have been granted under spurious grounds by judges, but any evidence obtained with such invalid warrants is not admissible in a trial. This is called the "exclusionary rule," for it excludes any evidence of a crime from beingpresented by prosecutors, no matter how damaging.
In May of 1978, a letter arrived at the police department of Bloomingdale, Illinois. The anonymous writer alleged that Bloomingdale residents Lance and Sue Gates were selling drugs from their home. The letter also provided a date on which the couple would travel to and return from Florida separately in order to ferry another shipment of contraband to their home for resale. Police investigated the Gates and their whereabouts, and confirmed that Lance Gates had flown to Florida and stayed in a motel room registered to his wife. Furtherinquiries revealed that Gates and an unidentified woman left the motel in acar with license plates registered to Gates, but for a different vehicle. With these details, Bloomingdale police obtained a warrant to search both the Gates residence as well as the car upon its arrival. They found 350 pounds of marijuana in the trunk of the car, and inside the house, more drugs and an unregistered firearm.
Invalid Warrant
Prior to Gates's trial, the respondents filed a motion to suppress the evidence, asserting the warrant that procured it had been obtained without "just cause." In legal terms, an anonymous tip is considered insufficient evidence for granting a search warrant. They were successful in this, and an appellate court upheld this decision suppressing all evidence. The Illinois Supreme Court also upheld the exclusion of evidence. All of these courts used two legal precedents in determining that the Bloomingdale police's search warrant was not valid. In the first, Aguilar v. Texas (1964), the courts had ruled that an informant's tip is enough to obtain a warrant if the police can determine the reliability of the source of this knowledge (for example, that the informant was a firsthand witness to it), and if the police can prove the informant's veracity in other areas. The Bloomingdale police's affidavit had neither.
Spinelli v. United States (1969), was another case used by courts to determine if a warrant was valid if it had not passed the requirements set forth in Aguilar v. Texas. Spinelli holds that there is "probablecause" to grant a warrant if some details provided by the tip are corroborated by police investigation, but if the informant presents evidence that may just be hearsay or rumor, this is not considered trustworthy. This was also a significant factor in barring evidence seized at the Gates home from incriminating them at their trial.
Hints of New Stance on Exclusionary Rule
The U.S. Supreme Court had ruled consistently in matters concerning the exclusionary rule since 1914. Again and again, it confirmed that evidence obtainedoutside proper legal means could not be used in a criminal trial. Yet by theearly 1980s, some conservatives had argued for exceptions to this rule. President Ronald Reagan asserted that the American people had lost faith in the legal system, viewing it as constrained by constitutional loopholes and unableto protect citizens from crime. He urged the granting of greater powers to law enforcement authorities to fight crime.
The State of Illinois asked the High Court to allow the drugs seized to be presented as evidence under a "good-faith" exception to the exclusionary rule.This exception took into account that the officers had acted in "good faith"that a crime had been committed; in other words, they believed they were operating within the law. Liberals, on the other hand, argued that granting a "good-faith" exception to the exclusionary rule would invent two separate realmsof the Constitution: one for citizens, who must abide by it, and another forlaw-enforcement authorities and the state, who were allowed to defy it. In other words, to adopt a good-faith exception to the exclusionary rule would endorse unconstitutional police behavior.
Decision, "With Apologies"
When Illinois v. Gates first appeared before the Supreme Court in October of 1982, the state of Illinois had requested that the High Court decide whether "probable cause" was present in the police affidavit that requested the warrant. The Illinois assistant attorney general later requested to enlargethe question to include whether or not such evidence was admissible in court, based on the "reasonable belief" that the search was valid under the FourthAmendment--even though it was later found not to be. After a few weeks, theSupreme Court motioned to return Illinois v. Gates to the docket, andit was re-argued in March of 1983.
On June 8 of that year, the Court issued its decision, with apologies. The good-faith clause had not been present in petitions to the lower courts,and the Supreme Court's task was to review the cases as they existed. It did, however, reverse the Illinois Supreme Court ruling barring the evidence against the Gates from trial. Justice Rehnquist's majority decision rejected theAguilar and Spinelli tests, and asserted that courts should abide by a "totality of circumstances" rule. This holds that a magistrate, presented with a police affidavit and request for warrant, should consider whether or not thereis a "fair probability" that evidence of a crime will be found at a specificplace, and found that the issuing judge and Bloomingdale police had acted within these precepts. Rehnquist also promised to look into modifying the exclusionary rule in three cases scheduled for the following term. Justices Brennan and Marshall dissented from the majority.
Related Cases
- Aguilar v. Texas, 378 U.S. 108 (1964).
- Spinelli v. United States, 393 U.S. 410 (1969).
- Kolendar v. Lawson, 461 U.S. 352 (1983).
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