to use one test to indicate if evidence is reliable. In the case of Illinois versus Gates, many of the Justices agreed to adopt the totality of circumstances standard for several reasons. Due to the simple fact that it is important to make sure evidence is being obtained from a trustworthy person, in this case specifically. They agreed that the “totality of circumstances” should be used since it is a more fluid concept instead of the “two-pronged test” which is strict. Having a fluid test, makes it