After The Washington Post broke

increasingly frustrated by Supreme Court decisions that limited the Justice Department's ability to prosecute people for their political opinions, most notably, Communists. At this time he formalized a covert "dirty tricks" program under the name COINTELPRO.[18]

This program remained in place until it was revealed to the public in 1971, and was the cause of some of the harshest criticism of Hoover and the FBI. COINTELPRO was first used to disrupt the Communist Party, and later organizations such as the Black Panther Party, Martin Luther King, Jr.'s SCLC, the Ku Klux Klan, the American Nazi Party and others. Its methods included infiltration, burglaries, illegal wiretaps, planting forged documents and spreading false rumors about key members of target organizations and flooding L.A. with drugs.[19] Some authors have charged that COINTELPRO methods also included inciting violence and arranging murders.[20] In 1975, the activities of COINTELPRO were investigated by the "United States Senate Select Committee to Study Governmental Operations with Respect to Intelligence Activities" called the Church Committee after its chairman, Senator Frank Church (D-Idaho) and these activities were declared illegal and contrary to the Constitution.[21] Hoover amassed significant power by collecting files containing large amounts of compromising and potentially embarrassing information on many powerful people, especially politicians. According to Laurence Silberman, appointed Deputy Attorney General in early 1974, FBI Director Clarence M. Kelley thought such files either did not exist or had been destroyed. After The Washington Post broke a story in January 1975, Kelley searched and found them in his outer office. The House Judiciary Committee then demande
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