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IT HAS BEEN POSTULATED by some researchers that the FBN's own desire to expand its jurisdiction ignited passage of the Marihuana Tax Act.1 Conversely, there is some evidence that Anslinger resisted federal legislation in order to protect his bureaucracy. In any event, the act did increase significantly the bureau's area of responsibility. In fact, as Dr. Woodward pointed out to the Ways and Means Committee, the bureau was economically incapable of securing full enforcement of the act. Hemp growing wild all over the country would have to be eradicated. Since medical distribution of the drug hatl all but disappeared, the contorted revenue-related devices employed in the act (written order forms, registration) bore no relation to the real world; the net effect was that simple possession now became a federal crime. Similarly, all nonmedical transfers , whatever the amount, circumstances, or geographical nature, were also' federal crimes. In a sense the Marihuana Tax Act blanketed existing state and local offenses with a coextensive range of federal offenses, all of these governing the same conduct.
Given the breadth of this statutory mandate, what did the bureau do? Anslinger began with a four-pronged enforcement policy when the act was passed:
1. Control of cultivation of the plant for legitimate purposes and eradication of wild growth
2. Pacification of marihuana sensationalism in the press
3. Education of the federal judiciary toward strict application of the law
4. Allocation of federal enforcement resources toward major trafficking rather than petty possession offenses
Crabgrass
The effort to control the legitimate growth and to eradicate the wild growth of marihuana was stymied from the outset. H. J. Wollner, consulting chemist to the Treasury Department, noted at once that "virtually nothing is known concerning the nature of the narcotic principle, its physiological behavior, and the ultimate effect upon the social group." Without some knowledge of the active principle, he went on, it was impossible to establish the presence of the psychoactive substance in a court of law, or to breed a strain which could serve the industrial purpose of cannabis without psychoactive properties.
With respect to "Marijuana: The Weed," Dr. Wollner observed:
As explained above, the plant marihuana is now growing wild in all parts of the country. It is to be anticipated that as the Bureau of Narcotics more effectively is in control of the legiti-mate growth, distribution, and use of this plant that the Bureau's attention shall be then directed toward the eradication and control of the wild growing weed.
To this end it would be desirable to know whether or not,the plant kingdom provides other species of plants, which, in respect to marihuana, would possess a weed eradicating character. It would be desirable to explore, in addition, the economics of a variety of weed killers to determine whether these can be practi-cally employed.2
The scope of marihuana's growth, the transportability and dormancy of the seeds, and the lack of a highly efficient herbicide all militated against a comprehensive eradication program. The cost of such a program would have been substantial even if success were assured. But the federal government simply was indisposed and un-equipped to conduct an acre-by-acre survey of the United States, and no active effort was undertaken. The eradication "program" became a matter of reaction to routine information—letters from farmers who had identified the plant and discoveries of acreage by law enforcement agents. As the bureau's interest in marihuana subsided during the forties, so did the effort to eradicate wild growth. In fact, the federal government encouraged the cultivation of hemp during the war, even though a chemically inactive strain had not been developed, because sources of sisal rope had been severed by Japan's occupation of the Philippines. All over the United States the weed remained plentiful and largely undetected.
No More Hysterics
The sensational accounts of the effects of marihuana in the press reached a crescendo around the time of the passage of the act. Although there had been a continuing debate within the medical and official communities about the prudence of encouraging such propaganda, Anslinger undoubtedly agreed with Dr. Walton's assertion that the situation required a "necessary degree of sen-sationalism." Walton, Anslinger, Gomila, and others tended to dismiss out of hand Woodward's contention that any increase in marihuana use was directly attributable to curiosity ignited by the press.
After the act, however, Anslinger changed his tune. Especially disastrous from the bureau's point of view was press interest in the same two matters which he had enthusiastically encouraged since 1935: the spread of use among the young, and its relation to violent crime. As propagandist, the bureau had since 1935 magnified use; now, as enforcer, the bureau found it politically expedient to minimize use. The goal was now one of deflecting public attention instead of attracting it.
The same change occurred in regard to the crime thesis. The major point of bureau propaganda against marihuana had long been its evocation of homicidal mania, and one of the primary sources of the bureau's evidence of the relation between marihuana use and violent crime had been the use of marihuana intoxication as a defense in criminal cases. Attempts by defense attorneys in an adversary setting to absolve the defendant of responsibility for his actions had become medical authority for the scientific hypothesis that marihuana use caused crime.3 This was also of tremendous interest to the press, especially in murder cases. Before the act, Anslinger had been somewhat ambivalent toward use of this defense tactic, but he did not attempt to discourage defense attorneys from asserting it. He was as willing to forward "atrocious crime" propa-ganda to them as to anyone else. One can well imagine how "useful as well as interesting" such an attorney found Anslinger's "Assassin of Youth" article, and how "gladly" he would pay "any necessary charges" for fifteen copies.4
State prosecutors, on the other hand, had been uneasy about the bureau's approach before passage of the act, for the FBN propaganda left very little room for rebuttal. If the drug, perhaps even one cigarette, removed all restraint and eradicated any moral distinctions between right and wrong, "temporary insanity" or "irresistible impulse" should relieve the defendant of complete responsibility, especially if possession and use of the substance were not illegal. Yet the state prosecutors were among Anslinger's most potent allies in his campaign to criminalize marihuana. This ambivalence is reflected in the letter which accompanied the gory photograph Anslinger used to tantalize the Senate Finance Sub-committee; to escape the dilemma, the prosecutor attributed the murder to the insidious effects of the drug, but noted that since the defendant's mind was not "totally prostrate," the verdict was "legally correct."5
After the act, Anslinger began to think more like a prosecutor than a propagandist. He wanted to put a stop to use of the defense and the hysteria it generated. He discouraged Dr. Munch, who had testified at the House hearings, from testifying on behalf of the defense in such situations.
Anslinger also directed his agents to discourage local officials from playing up any alleged involvement of marihuana with crime to the press. In a complete reversal of FBN policy, agents were noW alerted to the problem of yellow journalism.6 On 11 April 1938 the commissioner told his New York district supervisor that "our present policy is to discourage undue emphasis on marihuana for the reason that in some sections of the country recently press reports have been so exaggerated that interest in the subject has become almost hysterical and we are therefore trying to mold public opinion along more conservative and saner lines."7 Three days later Anslinger acquainted Dr. Munch with the new perspective:
I believe an article for King Features Syndicate would be bad publicity because of the fact that you cannot be sure as to what changes would be made in your article and your experience will only cause the curious to try it. We are now playing down pub-licity on marihuana as there are indications that the press has become somewhat hysterical on the subject and that as a number of articles which recently appeared have placed the problem all out of proportion to its present status in the field of narcotic control.°
The fact that Anslinger had accepted Woodward's view that sensational reports about marihuana would only lead children and impressionable youngsters to try the drug is also reflected in his revised concept of marihuana education. He came to feel very strongly that educational work should be conducted with consider-able discretion so that children could be warned in a way which would avoid arousing their curiosity about this drug. Similarly, when the Foreign Policy Association produced its pamphlet Mari-huana: The New Dangerous Drug, Commissioner Anslinger was heartened by assurances that the pamphlet would be placed only in the hands of mature adults and that no direct contact would be made with children.9
Put Them Away for Good
Immediately following passage of the act, the FBN directed an "educational" effort toward the federal judiciary which emphasized the need for severe sentences for marihuana offenders. Some judges needed no reinforcement. In one of the first cases under the act, a Colorado judge left no doubt about his view: "I consider mari-huana the worst of all narcotics—far worse than the use of morphine or cocaine. Under its influence men become beasts, just as was the case with [the defendant] . Marihuana destroys life itself. I have no sympathy with those who sell this weed. In the future I will impose the heaviest penalties. The Government is going to enforce this new law to the letter."1°
Some months later, however, the district supervisor in Phila-delphia reported that he and the U.S. attorney were perturbed because a federal judge had assessed only three years' probation to a reputed marihuana addict. Alleging that judges were unaware of the seriousness of marihuana addiction, he proposed that a con-ference be called for the purpose of educating judges on the importance of severe sentences to control the marihuana trade.11 Anslinger did encourage local "lobbying" efforts and they soon bore fruit. In 1938 the district supervisor for the Maryland, Virginia, and West Virginia areas reported "splendid results" in two recent narcotics cases handled in the western district of West Virginia.
The defendants in these cases were given ten- to twelve-year sentences for possession and growth of marihuana. Noting that the judge had been most cooperative in meeting his appeals for severe sentences in marihuana cases, the supervisor pointed out that his agents had spent a great deal of time addressing women's clubs in West Virginia in an effort to encourage public support for severe sentencing practices. Commissioner Anslinger was elated and he pledged to continue his efforts to educate judges to the need for harsh sentences.12 He wanted more judges to share the view ex- pressed by Judge McClintock in the West Virginia cases: "Anything more infernal than the trade of these people is hard to imagine."
No Big Deal
Without much initial guidance from Washington, FBN agents immediately began to arrest marihuana addicts whom they had formerly either ignored or turned over to state authorities. From 1 October to 31 December 1937 federal agents made 369 seizures totaling 229 kilograms of the drug.13 In so doing, however, the FBN personnel were only performing duties that state officials could have handled. Thus, on 14 December 1937 Commissioner Anslinger instituted a new policy in a confidential memorandum to all district supervisors:
The Bureau has noted that a great many marihuana cases of comparative minor nature are being reported.
Thus far, the courts have shown a very good attitude with regard to the disposition of marihuana cases and we do not wish to bring about a reaction by congesting court calendars with cases of a petty type. It is believed that in a great number of cases if more strenuous efforts were made to ascertain sources of supply, cases which could command more respect in the courts would be developed."
The commissioner hoped that the bureau's role in the enforce-ment of the Marihuana Tax Act would be to stifle suppliers, large interstate traffickers, and smugglers, while leaving the small pos-session cases to local authorities. However, several factors served to frustrate this policy. Of primary importance was the fact that marihuana traffic was highly disorganized and there was no national or regional network against which FBN expertise could be brought to bear.15 Second, the bureau had always exaggerated the incidence of use and the national proportions of the "problem." Use was still concentrated geographically and socioeconomically; commerce in the drug was a casual endeavor, not a major enterprise.
So, despite the commissioner's directive, the bureau's files are replete with reported apprehensions of individuals in possession of minute quantities of marihuana. In fact, in about half of all mari-huana cases reported and marihuana arrests made during the few years following passage of the act, the amount of marihuana possessed by the individual was less than one ounce, and no allegation of trafficking or sale was ever made.16 Once the United States entered World War II, enforcement activity declined sub-stantially; the Bureau of Customs and the FBN together seized only a total of 257 kilograms in 1945.17
By this time the bureau had again altered its policy, implicitly if not 'explicitly. Beginning during the war years, the bureau aban-doned responsibility for most marihuana law enforcement to the states. It chose instead to concentrate on the opiates. This policy became particularly firm after the war when narcotics use rose significantly. The bureau became increasingly selective with regard to the marihuana investigations it chose to launch, beginning to concentrate its efforts on the population it conceived to be most heavily involved, ghetto blacks and musicians.
The Jazz Threat
Ever since marihuana had first appeared in the major urban areas in the late twenties, the journeyman musical community had touted its beneficial effect on their performance. Many of the small-time and second-rate musicians who were arrested were heard to say, either at their trial or during the arrest process, that 'marihuana greatly improved their ability to play hot music and that a law ought to be passed to permit them to smoke marihuana. At the same time, the commissioner's public statements with regard to the role of jazz music and jazz musicians in spreading the marihuana habit to the young often brought him and the bureau in direct conflict with the musical world, especially its newspapers and union leaders.
In February 1938 two men were arrested outside Minneapolis for growing marihuana for the purpose of selling it. The Minne-apolis Tribune reported that Federal Narcotics Supervisor Joseph Bell had said: "Present day swing music, the Big Apple Dance, and orchestra jam sessions are responsible for increasing the use of marihuana, both by dance band musicians and by the boys and girls who patronize them." According to the Tribune, Bell went on to say, "the tempo of present day music [seems] to do some-thing to the nerves. [The] boys and girls . . . seem to think they need a stimulant for their nerves."18 The story prompted Sidney Berman, editor of a music magazine Orchestra World to complain to Commissioner Anslinger that "this is a rather serious charge against the popular orchestra field which we represent and we would appreciate further clarification on the subject."18 In response, Anslinger averred that the quotation from the Minneapolis Tribune had been made by the two men who had been arrested and not' by Agent Bell. In his own report to Commissioner Anslinger, however, Bell emphasized that, in his experience, many jazz musicians used marihuana and that the two men apprehended attested in detail to the fact that jazz musicians and jazz music were spreading a mari-huana culture among the young.28
In January 1941 the president of the Detroit Federation of Musicians announced on the front page of the union's official organ, Keynote, that "drastic action" had been taken to curb mari-huana use among the ranks: "Any member found guilty of the use of marihuana or on proof that a member uses same, such member shall immediately be expelled from membership."21 Wondering if smoke meant fire, Anslinger immediately directed his Detroit agents to determine the extent to which local musicians were engaged in the act of purveying marihuana among themselves or to others. Although the union resolution turned out to be largely precaution-ary,22 a subsequent arrest uncovered a large marihuana ring which had regularly sold quantities of the drug to bands traveling through or playing engagements in Detroit.23
Four weeks later a Los Angeles newspaper report that two local musicians who had been killed in an automobile accident had mari-huana cigarettes in their pockets24 prompted another letter to Anslinger from Berman of Orchestra World. He wondered whether the commissioner knew how much marihuana the musicians had or where they had gotten it.25 Anslinger replied that he was unable to comment on pending cases, although he noted in his personal file that "musicians appear to be among the principal users of mari-huana [and] a shock quote in Orchestra World may serve to jolt these people to the dangers of the use of this weed."26
A steady stream of such events together with the recession in the narcotics enforcement business during the war years provoked a major escalation in Anslinger's crusade against musicians in 1943. On 7 September the commissioner called for a nationwide roundup. He told all his field agents:
Because of increasing volume of reports indicating that many musicians of the swing band type are responsible for the spread of the marihuana smoking vice, I should like you to give the .problem some special attention in your district. If possible, I should like you to develop a number of cases in which arrest would be withheld so as to synchronize these with arrests to be made in other districts.
Please let me know what are the possibilities along this line in your district.27
As it turned out, the possibilities were slight. Most of the agents reported that there were few cases involving any big name musicians and that most of the smaller, less well known part-time musicians had already been arrested and their cases processed. Nevertheless, Anslinger kept alive the idea of a national roundup of jazz musicians throughout the 1940s. Each time a musician was alleged to smoke marihuana, particularly if his group were well known or had a large following among young people, the commissioner would send letters to all agents urging them to prepare a number of cases so that a nationwide, synchronized arrest could be executed.
One such incident was a birthday party for Tommy Dorsey during the fall of 1944, which ended in a major brawl. One of the guests, a Mr. Hall, testified before the California State Grand Jury that Dorsey had hit him and also smoked "the wrong kind of cigarettes." Apprised of this testimony, Anslinger urged his local agents to interview Hall and to encourage the state's attorney to determine whether Dorsey or members of his band might be in-volved with the use of marihuana. At first Hall was reluctant to say anything, and the prosecutor, not anxious to anger his only witness, asked the FBN to defer its investigation until the assault case was closed. The agents persevered, however, and finally they were per-mitted to interview Hall. He was unable to recall anything about the use of marihuana at the Dorsey party, and he said that he had never stated that Dorsey was in any way connected with marihuana. Stymied, the bureau dropped its investigation of the Dorsey band.28
Contributing to the bureau's heightened interest in the musical community was the conviction that musicians were draft dodgers. The marihuana laws thus became a tool for supporting the war effort. The commissioner asked the Selective Service System to prepare a list of musicians whose alleged marihuana use had ex-empted them from the draft. The list contained the names of many prominent musicians of the time, including Thelonius Monk. Anslinger had his agents prepare from this list an additional one designating the orchestras with which the rejectees were associated. These groups, of course, did not necessarily have any connection with marihuana; nevertheless, bands associated with the following entertainers and programs found their way into the official investi-gative files of the bureau: Louis Armstrong, Les Brown, Count Basie, Cab Calloway, Jimmy Dorsey, Duke Ellington, Dizzy Gillespie, Lionel Hampton, Andre Kostelanetz, the Milton Berle program, the Coca-Cola program, Jackie Gleason, and the Kate Smith program. As a result of these compilations, Anslinger wrote to his district supervisors on 19 December 1944:
I have in mind such cases as that of . . . . Not only is this man not in the Army where he belongs but he brazenly tells us that he is able to maintain an almost constant supply of mari-huana. I am transmitting a schedule prepared in the file room here which shows some of musicians (and their orchestral connections) who have been rejected by the military as marihuana users.
I wish you would study this and give any suggestions which you may have for dealing with the law violations upon which these men appear to be capitalizing.29
Such efforts were doomed, Anslinger soon discovered, by the unwillingness of anyone inside the jazz world to become an in-formant.3° On the whole the bureau's musicians crackdown during the war netted only itinerants or musicians of little fame. Much hearsay about big names such as Louis Armstrong, Sarah Vaughn, and Buddy Rich was gathered, but nothing ever came of it.31 After the war, however, the bureau's interest intensified. Commissioner Anslinger recommended to the under secretary of the treasury on 22 November 1948 that the following letter be sent to the head of the federation to which any person convicted of a narcotics vio-lation belonged:
Arrests involving a certain type of musician in marihuana cases are on the increase. The following are few of the many cases cited as examples: [names omitted].
As you know, some of these musicians acquire following among juveniles. We are all familiar with the type of hero wor-ship in which the juvenile is a slavish imitator of the things good or bad which are done by the object of his admiration.
In my opinion, there is a real juvenile delinquency threat in the marihuana antics of these persons. We, of course, are using all of the limited law enforcement facilities at our command.
I am bringing this situation to your attention because I feel that you might suggest ways in which your organization could assist in eliminating the anti-social activities of this segment of the musician profession. Hoping you can assist us in suppressing this abuse, I am Cordially H. J. Anslinger.32
Under Secretary Foley scrapped the idea because of its vagueness and the likelihood that it would raise a public outcry. He also doubted that the American Federation of Musicians would go along voluntarily.
The same year Anslinger observed before the House Ways and Means Committee: "We have been running into a lot of traffic among these jazz musicians and I am not speaking about the good musicians but the jazz type."33 This broadside provoked an outcry from the musical profession to the effect that jazz music was good music and only a very small segment of jazz musicians had ever been alleged to have been involved with marihuana. Downbeat magazine called for a public apology.34
The commissioner tried another tack three years later. He proposed that the Department of State cancel the passports of musicians who had at any time been involved in a court proceeding relating to marihuana. Three musicians were singled out for par-ticular scrutiny, one of them Thelonius Monk. This idea surfaced in the course of a casual conversation in Europe between an FBN agent and a prominent music personality. The musician observed that jazz music was becoming popular in Sweden and France and that the indigenous jazz musicians were emulating Americans not only in their musical tastes but also in their smoking habits. He also noted that the traveling American musicians were the only source of marihuana for their European colleagues. Despite Anslinger's contention that passport revocation would avoid embarrassment in the international arena, the Treasury Department rejected the scheme as too vague. It appears that the under secretary of the treasury felt that the allegations against the musicians were not sufficiently supportable to merit communication with the Depart-ment of State.35
In 1937 Anslinger had made the case for federal marihuana legislation, a matter that had been considered within the narcotics bureaucracy since 1930. He had convinced a willing, uninterested Congress that federal expertise and power were necessary to curb an emerging national menace which the states were unable to con-trol. Public opinion, he had alleged, had been aroused by an alarming increase in use of a disastrous narcotic weed which grew wild all over the country and was purveyed to school children and criminals by an organized interstate trafficking network.
Between 1938 and 1951 Anslinger defused the public "furor" that the bureau had helped create and then discovered that he could not eradicate the weed—which Woodward had predicted—and that there was no organized interstate traffic in the drug. Thus, the federal government had flexed its muscles to no avail; there was no opponent in the ring. This potent legislation—which had been so urgently needed—was ultimately turned upon a selected group of users who offended the FBN commissioner for reasons quite apart from their marihuana use. A law rooted in prejudice against one social group had become an instrument of prejudice against another.
Notes
1. Dickson, "Bureaucracy and Morality: An Organizational Perspective on a Moral Crusade," Social Problems, 16 (1968), 143.
2. Memorandum from Wollner to Anslinger, 14 Feb. 1938.
3. See, e.g., State v. Diaz, 76 Utah 463, 200 P. 727 (1930), where a defendant in a first-degree murder prosecution tried to disprove the requisite mens rea by showing that he was under the influence of marihuana at the time of the offense. Diaz had claimed that "his mind was an entire blank as to all that happened to him and stated that after smoking the marijuana he became 'very crazy.' " To corroborate his assertion, defendant summoned a physician whose testimony was summarized by the court: "He stated that [marihuana] is a narcotic and acts upon the central nervous system affecting the brain, producing exhilarating effects and causing one to do things which he otherwise would not do and especially induces acts of violence; that violence is one of the symptoms of an excessive use of marijuana... ; that the marijuana produces an don't care' effect. A man having used liquor and marijuana might deliberately plan a robbery and killing and carry it out and escape, and then later fail to remember anything that had occurred." In a later case, State v. Navaro, 83 Utah 6, 26 P.2d 955 (1933), the court rejected a constitutional attack by expounding on the evils of the drug; in this connection, the court relied heavily on the physician's testimony in Diaz.
4. Sidney Benbow to Anslinger, 7 July 1937, quoted in Senate, Hearings on H.R. 6906, p. 11.
5. Richard Hartshorne to Charles Schwarz, 18 Mar. 1937; quoted in Senate, Hearings on H.R. 6906, p. 11.
6. See letters from district supervisors to Anslinger, 12 Nov. 1938, 24 Sept. 1938, 2June 1938, 14June 1938, 16Jan. 1939, 1 Dec. 1938.
7. Anslinger to Williams, 11 Apr. 1938.
8. Anslinger to Munch, 14 Apr. 1938.
9. Anslinger to Williams, 4 June 1938.
10. Judge J. Foster Symes, quoted in Traffic in Opium and Other Dangerous Drugs (Washington, D.C.: GPO, 1937), p. 57.
11. District supervisor of Philadelphia to Anslinger, 5 Feb. 1938.
12. D. B. Martin to Anslinger, 19 Nov. 1938. File no. 0380-9-M.
13. Traffic in Opium (1937), p. 80. For a full and effective discussion of the flaws in these drug statistics from 1937 until the mid-1940s due to a confusion over what parts of the marihuana plant were to be weighed in determining how much of the drug had been seized, see Mandel, "Problems with Official Drug Statistics," Stanford Law Review, 21 (1969), 998-99.
14. Confidential memorandum from Anslinger to all district supervisors, 14 Dec. 1937.
15. The La Guardia Report concluded in 1944 that "the sale and distribution of marihuana is not under the control of any single orpnized group." Mayor's Committee on Marihuana, The Marihuana Problem in the City of New York (New York: Jaques Cattell, 1944), p. 25 (hereafter cited as La Guardia Report).
16. See Federal Bureau of Narcotics File no. 04 80-36-22, Book 1; File no. 1245, Book 1.
17. See chap. 11, inf. n. 35.
18. Minneapolis Tribune, 11 Feb. 1938.
19. Berman to district supervisor, New York, N.Y., 11 Feb. 1938. File: Marijuana and Musicians, 1938-53 (hereafter referred to as M & M).
20. Joseph Bell to Berman, 15 Feb. 1938; letter from Bell to Anslinger, 23 Feb. 1938. File: M & M.
21. Detroit Federation of Musicians, Keynote, Jan.-Feb. 1941. File: M & M.
22. Thomas W. Andrew, FBN agent, to Ralph H. Oyler, 19 Mar. 1941.
23. Memorandum for files from Anslinger.
24. Los Angeles Daily News, 22 Aug. 1941.
25. Berman to Anslinger, 8 Sept. 1941.
26. Memorandum for files from Anslinger.
27. Anslinger to all district supervisors, 7 Sept. 1943.
28. Joseph A. Manning, district supervisor, to Anslinger, 11 Nov. 1944, 9 Nov. 1944, 7 Oct. 1944, 5 Oct. 1944.
29. Anslinger to all district supervisors, 19 Dec. 1944.
30. R. W. Artis, district supervisor, to Anslinger, 9 Feb. 1945.
31. Memorandum Report, Bureau of Narcotics, New York, N.Y., 4 May 1953.
32. Draft letter by Anslinger, 22 Nov. 1948.
33. Testimony of Anslinger before House Ways and Means Committee, 1 Mar. 1949.
34. Downbeat, April 1949, p. 10.
35. Memorandum, Bureau of Narcotics, District 2, from John T. Cusack, agent, 7 Nov. 1951; Anslinger to M. Sicot, secretary general, International Criminal Police Commission, 26 Feb. 1951; memorandum from Anslinger to agent, returned with "too vague" scrawled across it, 27 Nov. 1951.
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