The Anonymous Letter

In May 1978, police in Bloomingdale, Illinois received an anonymous handwritten letter claiming the Defendant and his wife made their living selling drugs. It predicted his wife would drive their car to Florida and leave it there to be loaded with drugs, that the Defendant would then fly down and drive the car back, and that the trunk would be loaded with drugs on his return. A detective learned the Defendant had booked a flight from Chicago to West Palm Beach, Florida, and surveillance confirmed he flew there and went to a motel room registered to his wife; the next morning the two were seen leaving together in a car with Illinois plates, heading north. A magistrate reviewed the letter and the detective's affidavit describing this surveillance and issued a warrant. Upon their return, officers searched the car's trunk and found roughly 350 pounds of marijuana; a search of the house turned up more marijuana, weapons, and other contraband. At issue is whether the tip, corroborated only by these travel observations, gave the magistrate enough basis to issue the warrant.