Frankfurter's activities continued to attract attention for their alleged radicalism. In November 1919, he chaired a meeting in support of American recognition of the newly created Soviet Union. In 1920, Frankfurter helped to found the American Civil Liberties Union. Following the arrest of suspected communist radicals in 1919 and 1920 during the Palmer raids, Frankfurter, together with other prominent lawyers including Zechariah Chafee, signed an ACLU report which condemned the "utterly illegal acts committed by those charged with the highest duty of enforcing the laws" and noted they had committed entrapment, police brutality, prolonged incommunicado detention, and violations of due process in court. Frankfurter and Chafee also submitted briefs to a habeas corpus application to the Massachusetts Federal District Court. Judge George W. Anderson ordered the discharge of twenty aliens, and his denunciation of the raids effectively ended them. It was during this time that J. Edgar Hoover followed Frankfurter, referring to him as "the most dangerous man in the United States", and describing him in a report as a "disseminator of Bolshevik propaganda"