Aguilar-Spinelli test in Connecticut

44 Connecticut opinions name it 3 courts 1984–2021 2 in the last five years

The cases below were cited by Connecticut courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (16)

Case	Followed	Cited
Spinelli v. United Statesred scotus · 1969 · cited in 10 Connecticut opinions naming this issue, 1984–2021 2 sentences 1996For that reason, the fact patterns of cases discussed herein are not necessarily relevant and may not be fully described.) In State v. Barton, Id., the Supreme Court reviewed the Connecticut and federal law on arrests and searches based on information provided by unnamed informants, and the following is a synopsis of that review: Aguilar v. Texas, 378 U.S. 108 (1964), and Spinelli v. United States, 393 U.S. 410 (1969), established the two-pronged Aguilar-Spinelli test for determining whether information provided by a confidential informant constitutes probable cause. 1996For that reason, the fact patterns of cases discussed herein are not necessarily relevant and may not be fully described.) In State v. Barton, Id., the Supreme Court reviewed the Connecticut and federal law on arrests and searches based on information provided by unnamed informants, and the following is a synopsis of that review: Aguilar v. Texas, 378 U.S. 108 (1964), and Spinelli v. United States, 393 U.S. 410 (1969), established the two-pronged Aguilar-Spinelli test for determining whether information provided by a confidential informant constitutes probable cause.	4	10
State v. Kimbrogreen conn · 1985 · cited in 20 Connecticut opinions naming this issue, 1985–2021 2 sentences 2021In State v. Kimbro, 197 Conn. 219, 236 , 496 A.2d 498 (1985), overruled in part by State v. Barton, 219 Conn. 529 , 594 A.2d 917 (1991), a divided Supreme Court3 concluded, as a matter of state constitutional law, that article first, § 7, required application of ‘‘the more spe- cific standards of the Aguilar-Spinelli test’’;4 see Aguilar v. Texas, 378 U.S. 108 , 84 S. Ct. 1509 , 12 L. 2021In State v. Kimbro, 197 Conn. 219, 236 , 496 A.2d 498 (1985), overruled in part by State v. Barton, 219 Conn. 529 , 594 A.2d 917 (1991), a divided Supreme Court3 concluded, as a matter of state constitutional law, that article first, § 7, required application of ‘‘the more spe- cific standards of the Aguilar-Spinelli test’’;4 see Aguilar v. Texas, 378 U.S. 108 , 84 S. Ct. 1509 , 12 L.	2	20
State v. Ruscoegreen conn · 1989 · cited in 4 Connecticut opinions naming this issue, 1990–1999 2 sentences 1994Even under the Aguilar-Spinelli test where the reliability of the confidential informant was insufficient, probable cause would still be found if the warrant application affidavit set forth other circumstances — typically independent police CT Page 4235 corroboration of certain details provided by the informant — that bolster the deficiencies State v. Ruscoe, 212 Conn. 223 , 229 (1989), cert. denied, 493 U.S. 1084 , 110 S.Ct. 1144 , 107 L.Ed.2d 1049 (1990). 1994Even under the Aguilar-Spinelli test where the reliability of the confidential informant was insufficient, probable cause would still be found if the warrant application affidavit set forth other circumstances — typically independent police CT Page 4235 corroboration of certain details provided by the informant — that bolster the deficiencies State v. Ruscoe, 212 Conn. 223 , 229 (1989), cert. denied, 493 U.S. 1084 , 110 S.Ct. 1144 , 107 L.Ed.2d 1049 (1990).	1	4
Big Eagle v. United Statesgreen scotus · 1990 · cited in 4 Connecticut opinions naming this issue, 1990–1999 2 sentences 1994Even under the Aguilar-Spinelli test where the reliability of the confidential informant was insufficient, probable cause would still be found if the warrant application affidavit set forth other circumstances — typically independent police CT Page 4235 corroboration of certain details provided by the informant — that bolster the deficiencies State v. Ruscoe, 212 Conn. 223 , 229 (1989), cert. denied, 493 U.S. 1084 , 110 S.Ct. 1144 , 107 L.Ed.2d 1049 (1990). 1994Even under the Aguilar-Spinelli test where the reliability of the confidential informant was insufficient, probable cause would still be found if the warrant application affidavit set forth other circumstances — typically independent police CT Page 4235 corroboration of certain details provided by the informant — that bolster the deficiencies State v. Ruscoe, 212 Conn. 223 , 229 (1989), cert. denied, 493 U.S. 1084 , 110 S.Ct. 1144 , 107 L.Ed.2d 1049 (1990).	1	4
Rodriguez v. United Statesgreen scotus · 1990 · cited in 4 Connecticut opinions naming this issue, 1990–1999 2 sentences 1994Even under the Aguilar-Spinelli test where the reliability of the confidential informant was insufficient, probable cause would still be found if the warrant application affidavit set forth other circumstances — typically independent police CT Page 4235 corroboration of certain details provided by the informant — that bolster the deficiencies State v. Ruscoe, 212 Conn. 223 , 229 (1989), cert. denied, 493 U.S. 1084 , 110 S.Ct. 1144 , 107 L.Ed.2d 1049 (1990). 1994Even under the Aguilar-Spinelli test where the reliability of the confidential informant was insufficient, probable cause would still be found if the warrant application affidavit set forth other circumstances — typically independent police CT Page 4235 corroboration of certain details provided by the informant — that bolster the deficiencies State v. Ruscoe, 212 Conn. 223 , 229 (1989), cert. denied, 493 U.S. 1084 , 110 S.Ct. 1144 , 107 L.Ed.2d 1049 (1990).	1	4
Ruscoe v. Connecticutgreen scotus · 1990 · cited in 4 Connecticut opinions naming this issue, 1990–1999 2 sentences 1994Even under the Aguilar-Spinelli test where the reliability of the confidential informant was insufficient, probable cause would still be found if the warrant application affidavit set forth other circumstances — typically independent police CT Page 4235 corroboration of certain details provided by the informant — that bolster the deficiencies State v. Ruscoe, 212 Conn. 223 , 229 (1989), cert. denied, 493 U.S. 1084 , 110 S.Ct. 1144 , 107 L.Ed.2d 1049 (1990). 1994Even under the Aguilar-Spinelli test where the reliability of the confidential informant was insufficient, probable cause would still be found if the warrant application affidavit set forth other circumstances — typically independent police CT Page 4235 corroboration of certain details provided by the informant — that bolster the deficiencies State v. Ruscoe, 212 Conn. 223 , 229 (1989), cert. denied, 493 U.S. 1084 , 110 S.Ct. 1144 , 107 L.Ed.2d 1049 (1990).	1	4
State v. Morrillgreen conn · 1987 · cited in 3 Connecticut opinions naming this issue, 1989–1994 2 sentences 1994"The Aguilar-Spinelli test . . . consists of two prongs: "`The issuing [judge] must be informed of (1) some of the underlying circumstances relied on by the person providing the information to the affiant; and (2) some of the underlying circumstances from which the affiant concluded (a) that the informant, whose identity need not even be disclosed, was credible, or (b) that his information was reliable.'" State v. Morrill, supra, 566 . 1994"The Aguilar-Spinelli test . . . consists of two prongs: "`The issuing [judge] must be informed of (1) some of the underlying circumstances relied on by the person providing the information to the affiant; and (2) some of the underlying circumstances from which the affiant concluded (a) that the informant, whose identity need not even be disclosed, was credible, or (b) that his information was reliable.'" State v. Morrill, supra, 566 .	1	3
State v. Perrygreen conn · 1985 · cited in 2 Connecticut opinions naming this issue, 1985–1992 2 sentences 1992After first accepting the Illinois v. Gates “totality of the circumstances” test; see State v. Perry, 195 Conn. 505, 508 , 488 A.2d 1256 (1985); State v. Gasparro, 194 Conn. 96, 106 , 480 A.2d 509 (1984); it later ruled that article first, § 7, of our state constitution required adherence to the Aguilar-Spinelli test. 1992After first accepting the Illinois v. Gates “totality of the circumstances” test; see State v. Perry, 195 Conn. 505, 508 , 488 A.2d 1256 (1985); State v. Gasparro, 194 Conn. 96, 106 , 480 A.2d 509 (1984); it later ruled that article first, § 7, of our state constitution required adherence to the Aguilar-Spinelli test.	1	2
State v. Bembergreen conn · 1981 · cited in 2 Connecticut opinions naming this issue, 1986–1987	1	2
State v. Velascogreen conn · 1999 · cited in 1 Connecticut opinions naming this issue, 2001–2001	1	1
State v. Fergusongreen conn · 1981 · cited in 1 Connecticut opinions naming this issue, 2001–2001	1	1
United States v. Arthur Pressleygreen ca8 · 1992 · cited in 1 Connecticut opinions naming this issue, 2001–2001	1	1
State v. Jonesgreen alaska · 1985 · cited in 1 Connecticut opinions naming this issue, 1993–1993	1	1
State v. Ryersongreen conn · 1986 · cited in 1 Connecticut opinions naming this issue, 1992–1992	1	1
Commonwealth v. Uptongreen mass · 1985 · cited in 1 Connecticut opinions naming this issue, 1991–1991	1	1
State v. Velezgreen connappct · 1989 · cited in 1 Connecticut opinions naming this issue, 1989–1989	1	1

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Connecticut. Read the followed side critically anyway.

Also cited on this issue (64)

Case	Cited	Years
State v. Delmonaco green conn · 1984 2 sentences 1990“The Aguilar-Spinelli test for reviewing a finding of probable cause consists of two prongs: ‘ “The issu ing [judge] must be informed of (1) some of the underlying circumstances relied on by the person providing the information to the affiant; and (2) some of the underlying circumstances from which the affiant concluded (a) that the informant, whose identity need not even be disclosed, was credible, or (b) that his information was reliable.” ’ State v. Delmonaco, 194 Conn. 331, 338 , 481 A.2d 40 , cert. denied, 469 U.S. 1036 , 105 S. Ct. 511 , 83 L. 1990“The Aguilar-Spinelli test for reviewing a finding of probable cause consists of two prongs: ‘ “The issu ing [judge] must be informed of (1) some of the underlying circumstances relied on by the person providing the information to the affiant; and (2) some of the underlying circumstances from which the affiant concluded (a) that the informant, whose identity need not even be disclosed, was credible, or (b) that his information was reliable.” ’ State v. Delmonaco, 194 Conn. 331, 338 , 481 A.2d 40 , cert. denied, 469 U.S. 1036 , 105 S. Ct. 511 , 83 L.	12	1986–1991
S. E. Johnson Co. v. Arthur S. Langenderfer, Inc. green scotus · 1984 2 sentences 1990“The Aguilar-Spinelli test for reviewing a finding of probable cause consists of two prongs: ‘ “The issu ing [judge] must be informed of (1) some of the underlying circumstances relied on by the person providing the information to the affiant; and (2) some of the underlying circumstances from which the affiant concluded (a) that the informant, whose identity need not even be disclosed, was credible, or (b) that his information was reliable.” ’ State v. Delmonaco, 194 Conn. 331, 338 , 481 A.2d 40 , cert. denied, 469 U.S. 1036 , 105 S. Ct. 511 , 83 L. 1990“The Aguilar-Spinelli test for reviewing a finding of probable cause consists of two prongs: ‘ “The issu ing [judge] must be informed of (1) some of the underlying circumstances relied on by the person providing the information to the affiant; and (2) some of the underlying circumstances from which the affiant concluded (a) that the informant, whose identity need not even be disclosed, was credible, or (b) that his information was reliable.” ’ State v. Delmonaco, 194 Conn. 331, 338 , 481 A.2d 40 , cert. denied, 469 U.S. 1036 , 105 S. Ct. 511 , 83 L.	12	1986–1991
Spaulding v. University of Washington green scotus · 1984 2 sentences 1990“The Aguilar-Spinelli test for reviewing a finding of probable cause consists of two prongs: ‘ “The issu ing [judge] must be informed of (1) some of the underlying circumstances relied on by the person providing the information to the affiant; and (2) some of the underlying circumstances from which the affiant concluded (a) that the informant, whose identity need not even be disclosed, was credible, or (b) that his information was reliable.” ’ State v. Delmonaco, 194 Conn. 331, 338 , 481 A.2d 40 , cert. denied, 469 U.S. 1036 , 105 S. Ct. 511 , 83 L. 1990“The Aguilar-Spinelli test for reviewing a finding of probable cause consists of two prongs: ‘ “The issu ing [judge] must be informed of (1) some of the underlying circumstances relied on by the person providing the information to the affiant; and (2) some of the underlying circumstances from which the affiant concluded (a) that the informant, whose identity need not even be disclosed, was credible, or (b) that his information was reliable.” ’ State v. Delmonaco, 194 Conn. 331, 338 , 481 A.2d 40 , cert. denied, 469 U.S. 1036 , 105 S. Ct. 511 , 83 L.	12	1986–1991
Berkovitz v. Islamic Republic of Iran green scotus · 1984 2 sentences 1990“The Aguilar-Spinelli test for reviewing a finding of probable cause consists of two prongs: ‘ “The issu ing [judge] must be informed of (1) some of the underlying circumstances relied on by the person providing the information to the affiant; and (2) some of the underlying circumstances from which the affiant concluded (a) that the informant, whose identity need not even be disclosed, was credible, or (b) that his information was reliable.” ’ State v. Delmonaco, 194 Conn. 331, 338 , 481 A.2d 40 , cert. denied, 469 U.S. 1036 , 105 S. Ct. 511 , 83 L. 1990“The Aguilar-Spinelli test for reviewing a finding of probable cause consists of two prongs: ‘ “The issu ing [judge] must be informed of (1) some of the underlying circumstances relied on by the person providing the information to the affiant; and (2) some of the underlying circumstances from which the affiant concluded (a) that the informant, whose identity need not even be disclosed, was credible, or (b) that his information was reliable.” ’ State v. Delmonaco, 194 Conn. 331, 338 , 481 A.2d 40 , cert. denied, 469 U.S. 1036 , 105 S. Ct. 511 , 83 L.	12	1986–1991
Aguilar v. Texas red scotus · 1964 2 sentences 2021In State v. Kimbro, 197 Conn. 219, 236 , 496 A.2d 498 (1985), overruled in part by State v. Barton, 219 Conn. 529 , 594 A.2d 917 (1991), a divided Supreme Court3 concluded, as a matter of state constitutional law, that article first, § 7, required application of ‘‘the more spe- cific standards of the Aguilar-Spinelli test’’;4 see Aguilar v. Texas, 378 U.S. 108 , 84 S. Ct. 1509 , 12 L. 2021In State v. Kimbro, 197 Conn. 219, 236 , 496 A.2d 498 (1985), overruled in part by State v. Barton, 219 Conn. 529 , 594 A.2d 917 (1991), a divided Supreme Court3 concluded, as a matter of state constitutional law, that article first, § 7, required application of ‘‘the more spe- cific standards of the Aguilar-Spinelli test’’;4 see Aguilar v. Texas, 378 U.S. 108 , 84 S. Ct. 1509 , 12 L.	10	1984–2021
State v. Barton green conn · 1991 2 sentences 2021In State v. Kimbro, 197 Conn. 219, 236 , 496 A.2d 498 (1985), overruled in part by State v. Barton, 219 Conn. 529 , 594 A.2d 917 (1991), a divided Supreme Court3 concluded, as a matter of state constitutional law, that article first, § 7, required application of ‘‘the more spe- cific standards of the Aguilar-Spinelli test’’;4 see Aguilar v. Texas, 378 U.S. 108 , 84 S. Ct. 1509 , 12 L. 2021In State v. Kimbro, 197 Conn. 219, 236 , 496 A.2d 498 (1985), overruled in part by State v. Barton, 219 Conn. 529 , 594 A.2d 917 (1991), a divided Supreme Court3 concluded, as a matter of state constitutional law, that article first, § 7, required application of ‘‘the more spe- cific standards of the Aguilar-Spinelli test’’;4 see Aguilar v. Texas, 378 U.S. 108 , 84 S. Ct. 1509 , 12 L.	9	1992–2021
Illinois v. Gates green scotus · 1983 2 sentences 2008In 1983, “[i]n Illinois v. Gates, supra, 462 U.S. 213 , the United States Supreme Court recognized an underlying flaw in the application of the Aguilar-Spinelli analysis. 2008In 1983, “[i]n Illinois v. Gates, supra, 462 U.S. 213 , the United States Supreme Court recognized an underlying flaw in the application of the Aguilar-Spinelli analysis.	9	1988–2008
Gray v. Lucas, Warden, Et Al. green scotus · 1983 2 sentences 1996Those prongs are: 1) Is there a "basis of knowledge" for the information provided, such as personal observation by the informant; and, 2) does the informant have veracity, or, in the alternative, has the information provided been shown in some manner (such as corroboration by independent police investigation) to be reliable; Illinois v. Gates, 462 U.S. 213 , reh. denied, 463 U.S. 1237 (1983), found the two-pronged Aguilar-Spinelli test overly restrictive and declared that, under the United States Constitution, if the two prongs cannot be met, probable cause CT Page 5256-ZZ can nonetheless stil 1996Those prongs are: 1) Is there a "basis of knowledge" for the information provided, such as personal observation by the informant; and, 2) does the informant have veracity, or, in the alternative, has the information provided been shown in some manner (such as corroboration by independent police investigation) to be reliable; Illinois v. Gates, 462 U.S. 213 , reh. denied, 463 U.S. 1237 (1983), found the two-pronged Aguilar-Spinelli test overly restrictive and declared that, under the United States Constitution, if the two prongs cannot be met, probable cause CT Page 5256-ZZ can nonetheless stil	4	1988–1996
State v. Jackson green conn · 1972 2 sentences 1988Ed. 2d 401 (1984), [quoting] State v. Jackson, 162 Conn. 440, 446 , 294 A.2d 517 , cert. denied, 409 U.S. 870 , 93 S. Ct. 198 , 34 L. 1988Ed. 2d 401 (1984), [quoting] State v. Jackson, 162 Conn. 440, 446 , 294 A.2d 517 , cert. denied, 409 U.S. 870 , 93 S. Ct. 198 , 34 L.	4	1986–1988
Dorsey v. United States green scotus · 1972 2 sentences 1988Ed. 2d 401 (1984), [quoting] State v. Jackson, 162 Conn. 440, 446 , 294 A.2d 517 , cert. denied, 409 U.S. 870 , 93 S. Ct. 198 , 34 L. 1988Ed. 2d 401 (1984), [quoting] State v. Jackson, 162 Conn. 440, 446 , 294 A.2d 517 , cert. denied, 409 U.S. 870 , 93 S. Ct. 198 , 34 L.	4	1986–1988
Varnell v. Beto green scotus · 1972 2 sentences 1988Ed. 2d 401 (1984), [quoting] State v. Jackson, 162 Conn. 440, 446 , 294 A.2d 517 , cert. denied, 409 U.S. 870 , 93 S. Ct. 198 , 34 L. 1988Ed. 2d 401 (1984), [quoting] State v. Jackson, 162 Conn. 440, 446 , 294 A.2d 517 , cert. denied, 409 U.S. 870 , 93 S. Ct. 198 , 34 L.	4	1986–1988
Seath v. Regulations & Permits Administration green scotus · 1983 2 sentences 1990Ed. 2d 527 , reh. denied, 463 U.S. 1237 , 104 S. Ct. 33 , 77 L. 1990Ed. 2d 527 , reh. denied, 463 U.S. 1237 , 104 S. Ct. 33 , 77 L.	3	1988–1990
Harris v. Harris green · 1916 2 sentences 1990Ed. 2d 527 , reh. denied, 463 U.S. 1237 , 104 S. Ct. 33 , 77 L. 1990Ed. 2d 527 , reh. denied, 463 U.S. 1237 , 104 S. Ct. 33 , 77 L.	3	1988–1990
State v. Respass green conn · 2001 2 sentences 2021When the information supplied by the informant fails to satisfy the Aguilar-Spinelli test, probable cause may still be found if the warrant application affidavit sets forth other circumstances— typically independent police corroboration of certain details provided by the informant—that bolster the deficiencies.’’ (Citation omitted; internal quotation marks omitted.) State v. Respass, 256 Conn. 164 , 174 n.12, 770 A.2d 471 , cert. denied, 534 U.S. 1002 , 122 S. Ct. 478 , 151 L. 2021When the information supplied by the informant fails to satisfy the Aguilar-Spinelli test, probable cause may still be found if the warrant application affidavit sets forth other circumstances— typically independent police corroboration of certain details provided by the informant—that bolster the deficiencies.’’ (Citation omitted; internal quotation marks omitted.) State v. Respass, 256 Conn. 164 , 174 n.12, 770 A.2d 471 , cert. denied, 534 U.S. 1002 , 122 S. Ct. 478 , 151 L.	2	2021–2021
Gray v. Knowles green scotus · 2001 2 sentences 2021When the information supplied by the informant fails to satisfy the Aguilar-Spinelli test, probable cause may still be found if the warrant application affidavit sets forth other circumstances— typically independent police corroboration of certain details provided by the informant—that bolster the deficiencies.’’ (Citation omitted; internal quotation marks omitted.) State v. Respass, 256 Conn. 164 , 174 n.12, 770 A.2d 471 , cert. denied, 534 U.S. 1002 , 122 S. Ct. 478 , 151 L. 2021When the information supplied by the informant fails to satisfy the Aguilar-Spinelli test, probable cause may still be found if the warrant application affidavit sets forth other circumstances— typically independent police corroboration of certain details provided by the informant—that bolster the deficiencies.’’ (Citation omitted; internal quotation marks omitted.) State v. Respass, 256 Conn. 164 , 174 n.12, 770 A.2d 471 , cert. denied, 534 U.S. 1002 , 122 S. Ct. 478 , 151 L.	2	2021–2021
Respass v. Connecticut green scotus · 2001 2 sentences 2021When the information supplied by the informant fails to satisfy the Aguilar-Spinelli test, probable cause may still be found if the warrant application affidavit sets forth other circumstances— typically independent police corroboration of certain details provided by the informant—that bolster the deficiencies.’’ (Citation omitted; internal quotation marks omitted.) State v. Respass, 256 Conn. 164 , 174 n.12, 770 A.2d 471 , cert. denied, 534 U.S. 1002 , 122 S. Ct. 478 , 151 L. 2021When the information supplied by the informant fails to satisfy the Aguilar-Spinelli test, probable cause may still be found if the warrant application affidavit sets forth other circumstances— typically independent police corroboration of certain details provided by the informant—that bolster the deficiencies.’’ (Citation omitted; internal quotation marks omitted.) State v. Respass, 256 Conn. 164 , 174 n.12, 770 A.2d 471 , cert. denied, 534 U.S. 1002 , 122 S. Ct. 478 , 151 L.	2	2021–2021
Galle v. Director, Office of Workers' Compensation Programs green scotus · 2001 2 sentences 2021When the information supplied by the informant fails to satisfy the Aguilar-Spinelli test, probable cause may still be found if the warrant application affidavit sets forth other circumstances— typically independent police corroboration of certain details provided by the informant—that bolster the deficiencies.’’ (Citation omitted; internal quotation marks omitted.) State v. Respass, 256 Conn. 164 , 174 n.12, 770 A.2d 471 , cert. denied, 534 U.S. 1002 , 122 S. Ct. 478 , 151 L. 2021When the information supplied by the informant fails to satisfy the Aguilar-Spinelli test, probable cause may still be found if the warrant application affidavit sets forth other circumstances— typically independent police corroboration of certain details provided by the informant—that bolster the deficiencies.’’ (Citation omitted; internal quotation marks omitted.) State v. Respass, 256 Conn. 164 , 174 n.12, 770 A.2d 471 , cert. denied, 534 U.S. 1002 , 122 S. Ct. 478 , 151 L.	2	2021–2021
State v. Novembrino green nj · 1987 2 sentences 1999In support of his contention that evidence (hat would have supported a finding of probable cause under the Aguilar-Spinelli test (i.e., evidence establishing an informant’s “veracity” or “reliability” and “basis of knowledge”) does not necessarily require a finding of probable cause under the totality of circumstances test, the defendant makes reference to the decision of the New Jersey Supreme Court in State v. Novembrino, 105 N.J. 95 , 519 A.2d 820 (1987). 1999In support of his contention that evidence (hat would have supported a finding of probable cause under the Aguilar-Spinelli test (i.e., evidence establishing an informant’s “veracity” or “reliability” and “basis of knowledge”) does not necessarily require a finding of probable cause under the totality of circumstances test, the defendant makes reference to the decision of the New Jersey Supreme Court in State v. Novembrino, 105 N.J. 95 , 519 A.2d 820 (1987).	2	1993–1999
State v. Jackson green wash · 1984 2 sentences 1991See also Commonwealth v. Upton, 394 Mass. 363, 373 , 476 N.E.2d 548 (1985) (rejecting the “ ‘unacceptably shapeless and permissive’ ” Gates approach and retaining the Aguilar-Spinelli test on state constitutional grounds); State v. Jackson, 102 Wash. 432, 435 , 688 P.2d 136 (1984) (retaining Aguilar-Spinelli under the Washington constitution in lieu of the “nebulous” Gates approach). 1991See also Commonwealth v. Upton, 394 Mass. 363, 373 , 476 N.E.2d 548 (1985) (rejecting the “ ‘unacceptably shapeless and permissive’ ” Gates approach and retaining the Aguilar-Spinelli test on state constitutional grounds); State v. Jackson, 102 Wash. 432, 435 , 688 P.2d 136 (1984) (retaining Aguilar-Spinelli under the Washington constitution in lieu of the “nebulous” Gates approach).	2	1991–1993
State v. Gasparro green conn · 1984 2 sentences 1992After first accepting the Illinois v. Gates “totality of the circumstances” test; see State v. Perry, 195 Conn. 505, 508 , 488 A.2d 1256 (1985); State v. Gasparro, 194 Conn. 96, 106 , 480 A.2d 509 (1984); it later ruled that article first, § 7, of our state constitution required adherence to the Aguilar-Spinelli test. 1992After first accepting the Illinois v. Gates “totality of the circumstances” test; see State v. Perry, 195 Conn. 505, 508 , 488 A.2d 1256 (1985); State v. Gasparro, 194 Conn. 96, 106 , 480 A.2d 509 (1984); it later ruled that article first, § 7, of our state constitution required adherence to the Aguilar-Spinelli test.	2	1985–1992
State v. Martin green connappct · 1984	2	1986–1989
State v. Garcia green connappct · 1986 2 sentences 1989The trial court considered the affidavit that supported the warrant according to the standards for probable cause set forth in State v. Kimbro, 197 Conn. 219, 236 , 496 A.2d 498 (1985), 2 which applied the two-pronged Aguilar-Spinelli test. 3 This test requires that a court analyze: “ ‘ “(1) the basis of the informant’s knowledge — the means by which he acquired his information, and (2) the underlying facts establishing either his general veracity or his reliability in the particular case.” ’ State v. Garcia, [ 7 Conn. App. 354, 358 , 508 A.2d 824 (1986)], quoting State v. Martin, 2 Conn. App. 1989The trial court considered the affidavit that supported the warrant according to the standards for probable cause set forth in State v. Kimbro, 197 Conn. 219, 236 , 496 A.2d 498 (1985), 2 which applied the two-pronged Aguilar-Spinelli test. 3 This test requires that a court analyze: “ ‘ “(1) the basis of the informant’s knowledge — the means by which he acquired his information, and (2) the underlying facts establishing either his general veracity or his reliability in the particular case.” ’ State v. Garcia, [ 7 Conn. App. 354, 358 , 508 A.2d 824 (1986)], quoting State v. Martin, 2 Conn. App.	2	1988–1989
Connecticut v. Martin green scotus · 1985	2	1986–1989
MacLeod v. County of Santa Clara green scotus · 1985	2	1986–1989
Valmet Oy v. Beloit Corp. green scotus · 1985 2 sentences 1989The trial court considered the affidavit that supported the warrant according to the standards for probable cause set forth in State v. Kimbro, 197 Conn. 219, 236 , 496 A.2d 498 (1985), 2 which applied the two-pronged Aguilar-Spinelli test. 3 This test requires that a court analyze: “ ‘ “(1) the basis of the informant’s knowledge — the means by which he acquired his information, and (2) the underlying facts establishing either his general veracity or his reliability in the particular case.” ’ State v. Garcia, [ 7 Conn. App. 354, 358 , 508 A.2d 824 (1986)], quoting State v. Martin, 2 Conn. App. 1989The trial court considered the affidavit that supported the warrant according to the standards for probable cause set forth in State v. Kimbro, 197 Conn. 219, 236 , 496 A.2d 498 (1985), 2 which applied the two-pronged Aguilar-Spinelli test. 3 This test requires that a court analyze: “ ‘ “(1) the basis of the informant’s knowledge — the means by which he acquired his information, and (2) the underlying facts establishing either his general veracity or his reliability in the particular case.” ’ State v. Garcia, [ 7 Conn. App. 354, 358 , 508 A.2d 824 (1986)], quoting State v. Martin, 2 Conn. App.	2	1986–1989
State v. Ross green conn · 1984	2	1985–1986
State v. Torres green conn · 1995	1	2001–2001
State v. Adams green conn · 1995	1	2001–2001
State v. Torres neutral connappct · 1995	1	2001–2001
State v. Velasco neutral connappct · 1998	1	2001–2001
State v. Duntz green conn · 1992	1	1998–1998
State v. Hunter neutral connappct · 1992	1	1998–1998
State v. Adams green sc · 1987	1	1993–1993
State v. Lang green idaho · 1983	1	1993–1993
State v. Stephens green ga · 1984	1	1993–1993
Schmitt v. State green fla · 1991	1	1993–1993
State v. Jaroma green nh · 1986	1	1993–1993
State v. Kelly green mont · 1983	1	1993–1993
State v. Ricci green ri · 1984	1	1993–1993
State v. Hlavacek green wva · 1991	1	1993–1993

Statutes the citing opinions construe

CT § Conn. Gen. Stat. § 21a-278 (13) CT § Conn. Gen. Stat. § 21a-279 (13) CT § Conn. Gen. Stat. § 54-94a (13) CT § Conn. Gen. Stat. § 21a-277 (9) CT § Conn. Gen. Stat. § 54-41c (6) CT § Conn. Gen. Stat. § 21a-267 (4) CT § Conn. Gen. Stat. § 51-199 (4) CT § Conn. Gen. Stat. § 53a-48 (4) CT § Conn. Gen. Stat. § 54-41b (4) CT § Conn. Gen. Stat. § 54-41m (4) CT § Conn. Gen. Stat. § 54-96 (4) CT § Conn. Gen. Stat. § 54-41d (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

NY 312 (1975–2025) MA 119 (1985–2025) WA 87 (1973–2023) TN 86 (1991–2025) CT 44 (1984–2021) CO 43 (1973–2021) TX 35 (1982–2012) NM 29 (1989–2025) PA 29 (1973–2018) AK 21 (1985–2016) IL 17 (1977–2006) GA 15 (1975–1992) ID 15 (1980–2012) MI 13 (1982–2021) AL 12 (1982–2004) CA 10 (1983–2017) VA 9 (1972–2011) UT 8 (1984–2003) FL 8 (1978–1995) MD 8 (1974–2007) VT 7 (1989–2018) OH 7 (1988–2025) DC 6 (1977–2017) MT 6 (1978–2020) NC 5 (1983–2008) OK 5 (1973–1991) SD 4 (1976–2006) OR 3 (1985–2020) RI 3 (1984–2001) MS 3 (1985–2007) LA 3 (1983–1983) DE 2 (2008–2018) NH 2 (1985–1986) WY 2 (1992–1993) ND 2 (1985–1988) IN 2 (1988–1988) MN 2 (1978–1985) IA 2 (1990–2022) NJ 2 (1987–1991)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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