Brief Fact Summary. The police received an anonymous letter outlining specific details about the Defendants, Gates and others (the “defendants”), plans to traffic drugs from Florida to Illinois. When the details were corroborated by the defendants’ actions, police obtained a search warrant and found drugs, weapons and other contraband in the defendants’ home and automobile.
Synopsis of Rule of Law. Where an anonymous tip is corroborated with actual police findings, a “totality of the circumstances” approach is an appropriate way of determining probable cause instead of using the two-pronged test of “veracity/reliability” and “basis of knowledge” from Spinelli v. United States, 393 U.S. 410 (1969). The Fourth Amendment of the United States Constitution (“Constitution”) requires no more than a finding by an issuing magistrate that there is a “substantial basis” that a search will uncover evidence of wrongdoing.
Issue. May a magistrate issue a valid warrant on the basis of an anonymous tip where there is no indicia of the informer’s “basis of knowledge” if the information contained in the tip is corroborated with police findings?