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.
Observed surface forms (1)
| Surface form | Occurrences |
|---|---|
| Illinois v. Gates | 0 |
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) NERFINISHED ⓘ |
| constitutionalProvision | Fourth Amendment to the United States Constitution NERFINISHED ⓘ |
| country |
United States of America
ⓘ
surface form:
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 of America
ⓘ
surface form:
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 NERFINISHED ⓘ |
| overrulesOrModifies | Aguilar–Spinelli test NERFINISHED ⓘ |
| party |
Lance Gates
NERFINISHED
ⓘ
Susan Gates NERFINISHED ⓘ |
| 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 NERFINISHED ⓘ |
| result | search warrant upheld under totality of the circumstances ⓘ |
| standardAnnounced | totality of the circumstances ⓘ |
| stateParty | Illinois NERFINISHED ⓘ |
| subjectMatter | use of an anonymous letter to establish probable cause ⓘ |
| topic |
anonymous informant tips
ⓘ
standards for issuing search warrants ⓘ |
Referenced by (1)
Full triples — surface form annotated when it differs from this entity's canonical label.
Illinois v. Gates
→
holding
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The rigid two-pronged Aguilar–Spinelli test is abandoned in favor of a more flexible totality of the circumstances approach.
ⓘ