Aguilar v. Texas

Supreme Court of the United States · 1964 · Criminal Procedure
378 U.S. 108 (1964)
Overruled by Illinois v. Gates (1983)
Updated
Criminal ProcedureSearch WarrantsProbable CauseFourth Amendmentsearch warrantinformanthearsay affidavitneutral and detached magistrate

Facts

Two Houston police officers sought a warrant to search petitioner's home for narcotics. Their affidavit stated only that they had received reliable information from a credible person and believed that heroin, marijuana, barbiturates, and other narcotics and narcotic paraphernalia were being kept at the premises for sale and use contrary to law. The magistrate issued the warrant, officers entered the house, and they seized petitioner while he was attempting to dispose of narcotics. At trial, petitioner objected to the evidence obtained through the warrant, but the objection was overruled and he was convicted.

Issue

Whether a search warrant may validly issue when the supporting affidavit states only that officers received reliable information from a credible person and believe narcotics are on the premises, without setting out the underlying circumstances supporting the informant's conclusion or the officer's claim of reliability.

Rule

Under the Fourth Amendment, as applied to the States through the Fourteenth Amendment, a magistrate may issue a search warrant only upon probable cause shown by facts or circumstances presented under oath or affirmation. When an affidavit is based on hearsay from an informant, it must inform the magistrate of some of the underlying circumstances from which the informant concluded that the items were where he claimed they were, and some of the underlying circumstances from which the officer concluded that the informant was credible or his information reliable; mere affirmance of suspicion, belief, or conclusion is insufficient.

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Test yourself

One of 10 multiple-choice questions for this case. Pick an answer to see why.
In Phoenix, Officer Elena Morris applied for a warrant to search Devin Cole's apartment for stolen laptops. Her sworn affidavit stated only that she had "received reliable information from a credible person" that the laptops were inside the apartment and that she believed they were there.

If Devin moves to suppress the laptops seized under the warrant, how should the court rule?

Explanation. A warrant may rest on hearsay, but the magistrate must be told some underlying circumstances showing both the informant's basis of knowledge and the reasons the officer deemed the informant credible or the information reliable. A bare assertion that the officer received reliable information from a credible person is only a conclusion and leaves the magistrate as a rubber stamp rather than an independent evaluator of probable cause.