Alice Catherine Evans service worker was protected by law. Alice became interested in the disease brucellosis and its relationship to fresh, unpasteurized milk. Alice's investigation focused on the organism "Bacillus abortus", known to cause miscarriages in animals. Alice learned that the microbe thrived in infected cows as well as animals that appeared healthy. The reports hypothesized that since the bacteria was found in cow's milk, a threat to human health was likely. Evans decided to investigate this; she wondered whether the disease in cows could be the cause of undulant fever in humans. She reported her findings to the Society of American Bacteriologists
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