What evidence must the government present in a wiretap application to establish that an authorized official approved the application, and what is the government's burden to rebut a defendant's claim of unauthorized approval?

QUESTION PRESENTED Title III of the Omnibus Crime Control and Safe Streets Act of 1968 outlines a procedural framework for the authorization and implementation of wiretaps. See 18 U.S.C. § 2510 et seq. Recognizing the extreme level of intrusiveness created by telephonic eavesdropping, Congress included a number of safeguards to curb overuse of the investigative technique and provided that communications that were unlawfully intercepted or were not supported by authorizations that complied with the statute are subject to suppression. 18 U.S.C. § 2518. Title III also provides that only a limited number of high-level individuals within the Department of Justice may authorize a wiretap application. 18 U.S.C. § 2516(1). This Court has strictly construed these requirements, holding that if someone other than an authorized official purports to approve a wiretap application, such application is invalid. United States v. Chavez, 416 U.S. 562, 570-71 (1974); United States v. Giordano, 416 U.S. 505, 533 (1974). The question presented here is: What evidence must the government present in a wiretap application to establish that an authorized official approved the application? And if a defendant makes a colorable argument that the application failed to establish that an authorized official in fact authorized it, what is the government’s burden to rebut the defendant’s claim? i