After the 9/11 terrorist attacks, Congress and President George W. Bush enact the Patriot Act, which increases the authority of intelligence agencies to gather information through searches of e-mail and phone communications as well as medical, library and financial records of individuals. One provision allowed the use of sneak-and-peek warrants, which let law enforcement conduct secret searches with the purpose of gathering foreign intelligence. The target did not have to be notified, and probable cause for the search was not required. U.S. District Judge Ann Aiken in Oregon strikes down this provision as well as one that allows secret wiretaps as violating the Fourth Amendment in the case U.S. v. Mayfield. Brandon Mayfield had been falsely accused of involvement in the 2004 Madrid train bombings. The FBI secretly searched his house numerous times before his arrest.