In Burdeau v. McDowell, 256 U.S. 465, 41 S.Ct. 574, 65 L.Ed. 1048 (1921) private detectives burglarized the defendant's office and blew open a safe at the behest of a former employee of the defendant. The Supreme Court upheld the admission of the documents noting that "the record clearly shows that no official of the federal government had anything to do with the wrongful seizure of the petitioner's property." 256 U.S. at 475, 41 S.Ct. at 576. The Court established one of the early exceptions to the exclusionary rule laid down in Weeks v. United States, 232 U.S. 383, 34 S.Ct. 341, 58 L.Ed. 652 (1914). It held that when no federal officer had anything to do with the wrongful seizure of an individual's property, or any knowledge thereof until several months thereafter, there was no invasion of the security afforded by the Fourth Amendment. 256 U.S. at 475, 41 S.Ct. 574. Further, the Court held that such materials, when turned over to the government by the private individuals who procured them, might be retained by the United States for use as evidence in the criminal prosecution of their owner. Id. at 476, 41 S.Ct. 574.