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Among the more notable Pinkertson cases were those in which dozens of union spies were used by the infamous Jay Gould to break a strike against the Texas and Pacific Railroads and when Pinkerton detective's were used in 1905 to involve labor leaders in the murder of ex-Governor Frank Steunenberg of Idaho. After Congress declared LABOR SPYING unconstitutional in 1937, the industrial division of the Pinkerton agency was officially dissolved.

Criminal Investigations, Michael D. Lyman, 6th edition. ISBN 978-0-13-506057-5. Page 8-9.

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Q: What used by the Pinkerton agency until it was declared unconstitutional by Congress in the 1930s?
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