In the time immediately preceding FISA, a number of courts squarely addressed the issue of "warrantless wiretaps". In both "United States v. Brown", 484 F.2d 418 (5th Cir. 1973), and "United States v. Butenko", 494 F.2d 593 (3rd Cir. 1974), the courts upheld warrantless wiretaps. In "Brown", a U.S. citizen's conversation was captured by a wiretap authorized by the Attorney General for foreign intelligence purposes. In "Butenko", the court held a wiretap valid if the primary purpose was for gathering foreign intelligence information.