Spinelli v. United States Case Brief Summary | Law Case Explained

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Spinelli v. United States | 393 U.S. 410 (1969)

A confidential informant working with the FBI claimed that William Spinelli was engaging in illegal gambling activities at an apartment in Saint Louis. But the tip was vague and lacked important details regarding the credibility of the claim and how the informant got the information. Would such a bare-bones tip be enough to obtain a search warrant under the Fourth Amendment? The United States Supreme Court addressed this issue in Spinelli versus United States.

After receiving the tip, FBI agents conducted surveillance on Spinelli. They followed Spinelli’s car as he drove from East Saint Louis, Illinois, to Saint Louis, Missouri, on four different days. Each time, Spinelli parked at an apartment complex and went inside a specific apartment. Agents learned that the apartment was rented in the name of another person and had two telephone numbers associated with it.

An agent applied for a search warrant for the apartment and an arrest warrant for Spinelli. The warrant application recounted the four times that Spinelli drove to the apartment, that the apartment was rented in another person’s name, and that the apartment had two telephone numbers. The application stated that Spinelli was known to the agent as a gambler and bookie for other gamblers and that a confidential informant had informed FBI agents that Spinelli was making illegal bets for gamblers using the two phone numbers associated with the apartment.

A federal judicial commissioner, the predecessor of a magistrate judge, issued a search warrant for the apartment and an arrest warrant for Spinelli. Agents executed the warrant and searched the apartment, in which they seized gambling paraphernalia. They arrested Spinelli, who was charged with interstate travel to promote illegal gambling.

Spinelli moved to suppress the evidence seized from the apartment under the Fourth Amendment. The federal district court denied the motion. A jury convicted Spinelli, and he was sentenced to federal prison.

On Spinelli’s appeal, the United States Court of Appeals for the Eighth Circuit, sitting en banc, affirmed his conviction. That court held that, looking at the totality of the circumstances, the information contained in the warrant application amounted to probable cause. Spinelli successfully petitioned the United States Supreme Court to review his case.

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