Illinois v. Gates and Aguilar v. Texas were two judicial guidelines in the United States Courts. The two pronged test is based on sufficient information that is given to the police. The veracity prong need the officer to have a reason to arrest victim if the source of information is credible and they furnished with enough information. The two prong test was established through Aguilar v Texas to determine whether the information given can be used to use a search warrant. The information given by the informant should be clear and good. On the two pronged test, the court ruled that the magistrate be informed on the underlying circumstances on the informant and the circumstances where the person making the affidavit made conclusion with the informant. The informant was not disclosed.
In Illinois v. Gates, the police received a letter that had information on the Defendants. The letter from an unknown source showed Gates and others had the intention of involving in drugs between Florida and Illinois. In addition, police obtained a court order due to the subtle elements. On investigation, the police found medications and weapons at the home and vehicles of the respondents. A reasonable jurisdiction would be acquired through the ‘‘totality of circumstances’’ approach would be the best way to determine the cause a part from using the two –pronged test of veracity. It would not also be applicable to use Spinelli v. United States’ basis of knowledge. This was different from the two-dimensional trial and premise of learning. The Fourth Amendment requires justice through significant premise and a proof of being guilty (Grano, 2014). There is flexibility in achieving better public and private interests that came from Aguilar and Spinelli as per Fourth Amendment. In Illinois v. Gates the Supreme Court of the United States made a ruling that abandoned the two-pronged test.
The two pronged test and totality of circumstances were different in the manner they effected. By applying the two pronged test the court requires to know the reliability of the informant and the basis of knowledge (Woollcott, 2015). The totality of circumstances seems to better as it entails determining whether the warrant was issued through anonymous tip. The two pronged test is seen as restrictive hence the totality of circumstances is the best to be applied. When applying the two pronged officer must have a good reason in making allegation and must prove it through investigation but this not the case with the totality of circumstances.
In the Aguilar v. Texas case, the court affirmed that the letter and warrant contained inadequate information that would enable determination of probable cause in order to issue a search warrant. This is because they failed to satisfy the two pronged test. The two pronged test was abandoned as it was rigid for the probable cause of issuing warranty and instead the ‘‘totality of circumstances’’ with informed probable cause was used. In addition, the court understood that Spinelli required the anonymous letter for reliability and satisfaction of the two requirements. The totality of circumstances was seen as consistency in treatment of the probable cause as compared to the rigidity of the tests in the informant’s information.
Spinelli was permitting the details that were to be used in conclusion of the informant in the Illinois Court Case. The court sited that he had the sentiments containing the reliable information but he anonymous letter did not provide enough information to make conclusion. The Illinois court thus made a conclusion that no show of any probable causes that was made.
Grano, J. D. (2014). Probable Cause and Common Sense: A Reply to the Critics of Illinois v. Gates. U. Mich. JL Reform, 17, 465.
Woollcott, A. P. (2015). Abandonment of the Two-Pronged Aguilar-Spinelli Test Illinois v. Gates. Cornell L. Rev., 70, 316.