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rd te ' lk € 9 J a Ul. S. Buren of Inhestigution Bepurinent of Justice 1206 Law & Finance Bldg., Pittsburgh, Pennsylvania. ben, ~ SILe are Kove tee i a ge ° November 18, 1932 Director Do Le tnited States Bureau of Investigation ashington, D. ¢, q Washington, D FEB 10 1933 Dear Sir: With further reference to my lettar dated Got- ober 31, 1932 in which I submitted suggestions for con- sideration with a view to improvement of the work of ths Bureau, please consider, if possible, the followirg sug- gestions slong the same line, ae Tne writer recently read an ppinion handed down by the United StatesySupreme Court on November 7, 1952 in the case entitled JaCkK*GERARDI and LOULSs “ROLFEXGEEIRDT, Petitioners vs. the United States of America, in which it was held, in substance, that the Victim in that case was not guilty with JACK GERSRDI of conspicary to violate the White Slave Traffie act, and it appeared that the opinion somewhat differed from the opinion expressed in the case of the United States vs. Holte, 236 U. S. 140, although associate Supreme Court Justice Stone, in delivering the opinion in the Gebardi case, distinguished between the two C&SOSe .»w dpm ete Although this Agent did not meke a brief of the opinion it is his recollection that in the GERARDI case it was held that the Victim cannot be held guilty of conspira- ey to violate the White Slave Traffic Act where she willing- ly accompanies the man from one state to another for immoral purposes, and it appeared to be the opinion of the Court that a female conspirator had to take an active and positive vert in planning and causing the interstate transportation in order to be guilty of conspiracy to violete the ect. The mere accompanying of & man from one state to another does not apparantly constitute a violation of the law unless the woman takes an active part in causing the transportation, such as planning the trip or furnishing or assisting in furnishing the means of transportation.