◆ SpookStack

SUMMARY Extensive file reviews disclosed only that x 4 the early use of microphones by the PBI is not recorded in any detail, It appears that microphones were used by the FBI in the late 1920's and early 1930's to obtain intelligence in criminal cases, Prior Bureau authoriza- tion for microphone installations was first required in 1938 and since that time Bureau headquarters has naine tained tight control over the field in the use of these devices, Over the years, the FBI continually sought legal advice from the Department concerning microphone installations and the admissibility of evidence obtained from them, In the early 1940's the Department relied on a significant Supreme Court decision, Goldman v. United States, which held that a microphone surveillance was not equivalent to an march and seizure prohibited by the Fourth Amendment, On the basis of this decision, Alexander Holtzoff, Special Assistant to the Attorney General, even advised that evidence obtained fron a microphone installed by trespass would be admissible, because a microphone surveillance was not equivalent to an illegal search and seizure,