The state contends that a letter from an anonymous informer, together with corroborating circumstances, was sufficient probable cause under Aguilar for issuance of a search warrant.
This case boils down to a factual dispute over whether it is more like Spinelli or Draper. Three Illinois courts decided that the corroboration in this case did not demonstrate that a tip in an anonymous letter provided probable cause. Although the tip ultimately proved correct, there was no reason to believe that the author of the letter would tell the truth, and the police investigation revealed no criminal activity. The Illinois S Ct might have reasonably found probable cause, based on the corroboration of several details in the letter. But its decision is not clearly in error, and this case is fact-bound. I recommend denial.
Preliminary Memorandum, Illinois v. Gates, 462 U.S. 213 (1983). Box 367, Harry A. Blackmun Papers, Manuscript Division, Library of Congress, Washington, D.C.