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United States v. Squillacote

221 F.3d 542 (2000)

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United States v. Squillacote

United States Court of Appeals for the Fourth Circuit
221 F.3d 542 (2000)

AR

Facts

Along with several others, Theresa Squillacote (defendant) was charged with engaging in clandestine intelligence work against the United States for over 20 years. Although Squillacote started working for East Germany, she attempted to work for several other Communist powers. During its investigation of Squillacote and her coconspirators, the government conducted 550 days of clandestine surveillance under the Foreign Intelligence Surveillance Act. To conduct the surveillance, the government filed more than 20 applications under the act, along with affidavits from the attorney general stating that the information regarding Squillacote and the conspiracy could harm national security. These applications contained evidence showing that Squillacote was an agent for a foreign power even after East Germany collapsed. Eventually, Squillacote was apprehended when the FBI set up a sting operation asking Squillacote to work for South Africa. Squillacote was convicted of crimes against the national defense. Squillacote appealed to the United States Court of Appeals for the Fourth Circuit, arguing that there was insufficient probable cause to find her an agent of a foreign power because East Germany had collapsed by the time the government had received its authorizations for surveillance under the act.

Rule of Law

Issue

Holding and Reasoning (Traxler, J.)

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