Review the three (3) cases provided in the the text (Draper v US, Spinelli v US, and Illinois v Gates). Compare and contrast these cases as to how they differ or are related. What are their significance when dealing with hearsay evidence? Brief outside research will be helpful.

Answer 1

The three cases provided in the text, Draper v US, Spinelli v US, and Illinois v Gates, have significance in the context of hearsay evidence and differ in their approach to establishing probable cause for search warrants. Let's review these cases and compare and contrast their outcomes.

1. Draper v US:
In Draper v US (1959), the Supreme Court ruled that hearsay information from an unidentified informant could establish probable cause for a search warrant if the information was demonstrated to be credible and reliable. The case involved an informant providing detailed and accurate information about the defendant's drug trafficking activities, which led to his arrest and seizure of narcotics.

2. Spinelli v US:
Spinelli v US (1969) challenged the use of an anonymous informant's tip as the sole basis for establishing probable cause for a search warrant. The Court held that additional independent corroboration of the tip's information was necessary to meet the probable cause requirement. In this case, an anonymous informant provided the police with information that the defendant was involved in illegal gambling activities, but no independent corroboration was obtained.

3. Illinois v Gates:
Illinois v Gates (1983) brought a change in the Supreme Court's approach to establishing probable cause. It eliminated the strict two-pronged test set by Spinelli and instead adopted a "totality of the circumstances" approach. The Court ruled that an anonymous tip, even without independent corroboration, could establish probable cause if the information provided exhibited sufficient indicia of reliability. The case involved an anonymous letter accusing the defendants of drug trafficking, which was corroborated by police investigations.

When considering their significance in relation to hearsay evidence, these cases reflect the evolving standards set by the Supreme Court. Draper v US established that hearsay from an unidentified informant can be used to establish probable cause if its credibility and reliability are demonstrated. Spinelli v US, on the other hand, required additional corroboration to support an anonymous informant's tip.

Illinois v Gates represented a departure from the strict rules of Spinelli and introduced a more flexible "totality of the circumstances" test. Under this test, an anonymous informant's tip, even without independent corroboration, can establish probable cause if the information provides enough indications of reliability.

These cases highlight the delicate balance between privacy rights and law enforcement needs in Fourth Amendment jurisprudence. While the cases differ in their outcomes, they collectively shape the approach to hearsay evidence and the establishment of probable cause, ensuring that reliable information is utilized while also preventing unchecked reliance on anonymous tips.