ABSTRACT

Illinois v. Gates began when Bloomington, Illinois, police received an anonymous letter containing detailed information about the interstate drug trafficking enterprise of Susan and Lance Gates. The letter stated that a one-way ticket was purchased between Chicago and West Palm Beach, Florida. One spouse would be met by the other, drugs loaded, and the contraband driven to Bloomington for resale. Anonymity made it impossible to fulfill either prong of the Aguilar- Spinelli test. Officers received corroborating information, however, from a security guard at O'Hare airport that Lance Gates had booked a one-way flight to West Palm Beach. The US Supreme Court agreed with the Illinois Supreme Court's ruling that the anonymous letter alone provided no basis for a magistrate to find probable cause. The court stated, "[T]he deficiency in one prong may be offset by a stronger than usual set of information in the other prong, thereby meeting the Fourth Amendment requirements.".