Alice Catherine Evans in 1917 and published her work in the "Journal of Infectious Diseases" in 1918. She was met with skepticism, particularly because she was a woman and did not have a Ph.D. She warned that raw milk should be pasteurized to protect people from various diseases. During the 1920s, scientists around the world made the same findings, and eventually, "Brucella" was confirmed as the disease that caused what was then known as undulant fever and Malta fever. Her findings led to the pasteurization of milk in 1930. As a result, the incidence of brucellosis in the United States was significantly reduced.
Federal Rules of Criminal Procedure to fill in, despite seeming authorization under the Judiciary Act to do so. Early Supreme Court cases also fully endorsed congressional authority to enact rules of procedure, and declined the opportunity to directly claim such authority for the courts under Article III of the United States Constitution. A few federal court decisions nonetheless established what amounted to particular federal common law rules of criminal procedure, which added to the lack of conformity in the federal system. In 1933, Congress authorized the Supreme Court to prescribe rules of criminal "appellate" procedure, which included any proceeding after the entry of a verdict