moved to suppress the warrant, or void it on the grounds that it was not constitutional. Ironically, the same judge that handed out the warrant was the one that heard the appeal for the warrant suppression. The Janis counsel held that Officer Weissman's affidavit was not convincing enough to warrant the search. They cited Spinelli v. United States, a case decided just before the issuing of the warrant that set precedent on how these warrants were to be approved. The Faulty Warrant Joining with Aguilar v. Texas, a case that established "hearsay" information was not enough to produce a warrant, a two-pronged test was established in 1969, known as the “Aguilar-Spinelli test”. The test required two crucial pieces of information: one being that the information supporting the necessity of the warrant is reliable and credible, and the other being that the circumstances of the surveillance must be made clear to the judge. Janis and Levine appealed on the grounds that the former, in that the affidavit supporting the warrant was inadequate. Both the District Court and the Ninth Circuit Court of Appeals held that the affidavit contained insufficient information and the evidence obtained by the warrant was therefore illegal. The government submitted a counterclaim to these rulings but it was quickly dismissed. Based on this, the Supreme Court granted certiorari. Logic of the Supreme Court The Court started by recognizing the central issue it faced. This issue was not question of illegally obtained evidence procured with a faulty warrant. The Court had already spoken several times on this issue and other issues related to the Fourth Amendment. Instead, the general question asks that if evidence seized by a state officer (Officer Weissman of the LAPD), but used by a federal department (the IRS) is admissible in a civil case - that being the one revolving around the tax assessment against Janis. The Court states that there are two separate pieces to the entire case. The first of these is the "refund suit". Max Janis appealed his conviction and wanted a refund of the $4,940 taken from him. The second part of the case is a “tax collection suit”. This is the government's counterclaim to recollect the taxes, which was quickly shot down by the Ninth Circuit Court of Appeals. The Court much discussed the “burden of proof”, or the need someone bears of proving themselves innocent. It was found that,