In 1886, the Supreme Court, in Wabash, St. Louis & Pacific Railway Company v. Illinois, found that the states had no power to regulate interstate commerce. The resulting Interstate Commerce Act of 1887 created a Federal responsibility for interstate law enforcement. The Justice Department, which had hired few permanent investigators since its establishment in 1870, made little effort to relieve its staff shortage until the turn of the century, when Attorney General Charles Joseph Bonaparte reached out to other agencies, including the Secret Service, for investigators. But the Congress forbade this use of Treasury employees by Justice, passing a law to that effect in 1908. The Attorney General moved to organize a formal Bureau of Investigation (BOI or BI), complete with its own staff of special agents. The Secret Service provided the Department of Justice 12 Special Agents and these agents became the first Agents in the new BOI. Thus, the first FBI agents were actually Secret Service agents. Its jurisdiction derived from the Interstate Commerce Act of 1887. The FBI grew out of this force of special agents created on July 26, 1908 during the presidency of Theodore Roosevelt. Its first official task was visiting and making surveys of the houses of prostitution in preparation for enforcing the "White Slave Traffic Act," or Mann Act, passed on June 25, 1910. In 1932, it was renamed the United States Bureau of Investigation. The following year it was linked to the Bureau of Prohibition and rechristened the Division of Investigation (DOI) before finally becoming an independent service within the Department of Justice in 1935. In the same year, its name was officially changed from the Division of Investigation to the present-day Federal Bureau of Investigation, or FBI.
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