In the first 3 years following the Gates decision, the Supreme Courts of Alabama, Arizona, Arkansas, Colorado, Georgia, Illinois, Maryland, Mississippi, Montana, North Carolina, and Pennsylvania adopted Gates as their State probable cause standard. Additionally, the supreme courts of 10 other States, while not expressly adopting Gates as the State constitutional standard, have cited Gates favorably, using it to evaluate and find probable cause in a State prosecution. Fewer than 10 State supreme courts, including those of Alaska, Connecticut, Massachusetts, and Washington, have rejected, totally or in part, the lesser standard of proof adopted by Gates. The reaction by States to the Gates opinion indicates that most State supreme court judges place a higher priority on search and seizure than on individual privacy rights. 198 footnotes.