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Aguilar v. Texas
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| Aguilar v. Texas | |
| Reference: 378 US 108 | |
| Term: 1964 | |
| Important Dates | |
| Argued: March 25-26, 1964 Decided: June 15, 1964 | |
| Outcome | |
| Texas Court of Criminal Appeals reversed | |
| Majority | |
| Earl Warren • William Douglas • John Harlan • William Brennan • Arthur Goldberg • Byron White | |
| Dissenting | |
| Hugo Black • Tom Clark • Potter Stewart | |
Aguilar v. Texas is a case that was decided on June 15, 1964, by the United States Supreme Court holding 6-3 that Houston police officers violated the reasonableness requirement outlined in the Fourth Amendment by executing a search warrant that was based on an affidavit from an unidentified and potentially unreliable source. The court reversed the decision of the Texas Court of Criminal Appeals.[1][2]
Why it matters: The Supreme Court's decision found that the Houston police officers violated the Fourth Amendment's reasonableness requirement, which specifies all searches conducted must be done within reason. The Fourth Amendment is incorporated under the Due Process Clause of the Fourteenth Amendment. This case established what was formerly known as the Aguilar-Spinelli test, which stated that search warrants could be granted on the basis of hearsay if they meet certain requirements.[3] The test was eventually discredited by the 1983 Supreme Court decision in Illinois v. Gates. To read more about the impact of Aguilar v. Texas, click here.
Background
In early January of the 1960s, two Houston police officers were surveilling the residence of an individual named Aguilar. Later that month, the officers applied for a search warrant, believing Aguilar possessed narcotics with the purpose of distributing and selling. This information was allegedly corroborated by an anonymous source with knowledge that narcotics were being kept within the residence. The police were granted the warrant by the judge. When the police went to execute the warrant, they heard a commotion inside the residence, causing the officers to forcibly enter. They arrested Aguilar and recovered narcotics that he was attempting to flush down the drain.
During his trial, Aguilar objected to the inclusion of evidence collected during the search. He argued that the search warrant's affidavit was "nothing more than hearsay." The state court dismissed Aguilar's argument and convicted him for illegally possessing heroin. Aguilar appealed the conviction to the Texas Court of Criminal Appeals. They affirmed the conviction.[2]
Oral argument
Oral arguments were held between March 25-26, 1964. The case was decided on June 15, 1964.[1]
Decision
The Supreme Court decided 6-3 to reverse the decision of the Texas Court of Criminal Appeals. Justice Arthur Goldberg delivered the opinion of the court. Justice John Harlan wrote a concurring opinion, while Justice Tom Clark authored a dissenting opinion, joined by Justices Hugo Black and Potter Stewart.[2]
Opinions
Opinion of the court
Justice Arthur Goldberg, writing for the court, argued that the search warrant should be declared void because the informant was not credible and the judge could not rely upon the facts presented by the officers to justify a probable cause to search Aguilar's residence:[2]
| “ | Here, the 'mere conclusion' that petitioner possessed narcotics was not even that of the affiant himself; it was that of an unidentified informant. The affidavit here not only 'contains no affirmative allegation that the affiant spoke with personal knowledge of the matters contained therein,' it does not even contain an 'affirmative allegation' that the affiant's unidentified source 'spoke with personal knowledge.' For all that appears, the source here merely suspected, believed or concluded that there were narcotics in petitioner's possession. The magistrate here certainly could not 'judge for himself the persuasiveness of the facts relied on . . . to show probable case.' He necessarily accepted 'without question' the informant's 'suspicion,' 'belief,' or 'mere conclusion.'[4] | ” |
| —Arthur Goldberg, majority opinion in Aguilar v. Texas[2] | ||
Concurring opinion
Justice John Harlan wrote a concurring opinion, stating he would have voted in favor of Texas but believed doing so would relax the Fourth Amendment's standards, which could have implications on the federal system.[2]
Dissenting opinion
Justice Tom Clark, joined by Justices Hugo Black and Potter Stewart, wrote a dissenting opinion critiquing the majority opinion's rigid interpretation of the Fourth Amendment's reasonableness requirement:[2]
| “ | Believing that the Court has substituted a rigid, academic formula for the unrigid standards of reasonableness and 'probable cause' laid down by the Fourth Amendment itself -- a substitution of technicality for practicality -- and believing that the Court's holding will tend to obstruct the administration of criminal justice throughout the country, I respectfully dissent.[4] | ” |
| —Tom Clark, dissenting opinion in Aguilar v. Texas[2] | ||
Impact
| Federalism |
|---|
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| •Key terms • Court cases •Major arguments • State responses to federal mandates • Federalism by the numbers • Index of articles about federalism |
Aguilar v. Texas established what was formerly known as the Aguilar-Spinelli test, which allowed search warrants to be granted on the basis of hearsay only if they meet certain requirements. The two requirements of the test were that (1) the judge must be informed of the reasons to support the conclusion that such an informant is credible; and (2) the judge must be informed of the underlying circumstances of the person providing the information. This test was later overturned in the 1983 U.S. Supreme Court decision in Illinois v. Gates.[3] [1][2]
See also
External links
- Full text of case syllabus and opinions (Justia)
- Supreme Court of the United States
- Search Google News for this topic
Footnotes
- ↑ 1.0 1.1 1.2 Oyez, "Aguilar v. Texas," accessed August 22, 2022
- ↑ 2.0 2.1 2.2 2.3 2.4 2.5 2.6 2.7 2.8 Justia, "Aguilar v. Texas, 378 U.S. 108 (1964)," accessed August 22, 2022
- ↑ 3.0 3.1 U.S. Legal, "Aguilar-Spinelli Test," accessed August 22, 2022
- ↑ 4.0 4.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
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