Case Brief #2
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Feb 20, 2024
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Spinelli v. United States
Audrianna Blackshear
Criminal Procedure and Evidence
Dr. Alex Ekwuaju
February 4, 2024
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Abstract
Spinelli v. United States (1969) was a significant Supreme Court case that proved a two-pronged test for deciding the validity of an informant's tip before issuing a search warrant. The Court figured out that the evidence used to obtain the warrant did not supply sufficient probable cause because it was based on an unsubstantiated and unclear tip that did not explain the basis of the informant's knowledge or the informant's tip. Based on the evidence obtained through the search warrant, the Court overturned Spinelli's conviction for illegal gambling.
Keywords: probable cause, search warrant, informant’s tip, illegal gambling
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Title:
Spinelli v. United States
Citation:
393 U.S. 410 (1969)
Year Decided
: 1969
Judge
: Justice John Marshall Harlan II
Facts
: Spinelli was convicted of interstate travel in aid of racketeering based on evidence
obtained through a magistrate's search warrant (Del Carmen & Hemmens, 2016, pg.77). The
warrant was based on an FBI agent's affidavit, which said that Spinelli was known as a
bookmaker, that he was seen crossing state lines and entering an apartment, and that a
confidential informant informed the FBI that Spinelli was operating a handbook and accepting
wagers by phone from the apartment (Del Carmen & Hemmens 2016, pg.77)
Procedural History
: Spinelli filed an appeal with the United States Court of Appeals for the Eighth Circuit, claiming that the search warrant violated the Fourth Amendment by not being supported by probable cause (Del Carmen & Hemmens, 2016, pg. 77). The Court of Appeals upheld his conviction, ruling that the affidavit met the principles of Aguilar v. Texas, 378 U.S. 108 (1964), which required the affidavit to prove the basis and veracity of the informant's tip. Spinelli filed a writ of certiorari with the United States Supreme Court, which granted it and agreed to review the case.
Issue: Was there enough probable cause in the affidavit to justify issuing the search warrant? No
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Court Decision: The Supreme Court overturned the conviction, ruling that the affidavit did not provide enough probable cause because it was based on an informant's tip that was not supported
by independent evidence or explained how an informant gathered the data.
Holding: The Court applied Aguilar v. Texas's two-pronged test, which requires the affidavit to prove the basis of the informant's knowledge as well as the informant's veracity or reliability (Del Carmen & Hemmens, 2016, pg. 77) The Court decided that the informant's tip in this case was insufficient under both prongs, and that the FBI's surveillance of Spinelli and investigation of the phone records did not independently indicate criminal behavior. The Court decided that the magistrate who issued the warrant lacked a substantial basis for determining probable cause, and that the evidence obtained through the search warrant should have been suppressed.
Dissenting Opinion
: Justice White dissented, claiming that the affidavit supplied probable cause
because it contained enough evidence to support a reasonable inference that Spinelli was participating in illegal gambling. Justice White criticized the majority for setting up a rigid and unrealistic standard for probable cause, as well as undermining the worth and reliability of informants' tips.
Case Significance: The case is significant because it clarified and increased the probable cause standards for search warrants set up by Aguilar v. Texas. The case also set up the "totality of the circumstances" strategy, which allows the magistrate to consider the different parts of the affidavit in arrangement, rather than in a state of isolation when deciding whether probable cause
exists. The case additionally played a role in the development of the "good faith" exception to the
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exclusionary rule, which allows evidence obtained under a defective warrant to be admitted if the
police worked in good faith and relied on the warrant.
Conclusion/Discussion/Policy Implication: In my review, the case was correctly decided because it protected the rights of the defendant from unreasonable searches and seizures and made sure that the magistrate's decision was based on reliable and verifiable information. The case also struck a balance between law enforcement and privacy concerns by allowing the use of informants' tips while requiring them to be backed up by more evidence or details. The case also recognized the importance of judicial discretion and common sense by using a "totality of the circumstances" approach rather than a set of rules for probable cause.
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Reference
Carmen, R.V. D., & Hemmens, C. (2016). Criminal Procedure: Law and Practice (10th ed.). Cengage Limited. https://reader.yuzu.com/books/9781337472395
Reference
: Rolando V. del Carmen; Craig Hemmens (2017). Boston, MA; Cengage Learning
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