Her authority was widely acknowledged and rarely challenged with success. Decisions of the Passport Division were not subject to judicial review during her years of service and her authority was described as "limitless discretion."Kent v. Dulles (1958) established judicial review of passport decisions. Kahn, "Extraordinary," 822 Bill Donovan of the Office of Strategic Services (OSS) first tried to win favor with Shipley by hiring her brother. When she nevertheless insisted on identifying OSS agents by noting "on Official Business" on their passports, Donovan had to get President Roosevelt to reverse her.Douglas Waller, Wild Bill Donovan: The Spymaster Who Created the OSS and Modern American Espionage (NY: First Free Press, 2011), 99; Joseph E. Persico, Roosevelt's Secret War: FDR and World War II Espionage (NY: Random House, 2002), 187 Her efforts to deny travel privileges to the children of U.S. diplomats were similarly overridden in the years following World War II.Kahn, "Extraordinary," 861
