which had been Brown's original goal as incentive for developing new technologies, increasing safety, and growth of the American aircraft manufacturing industry. Throughout the Black Committee process and a smaller, parallel investigation by the Justice Department directed by special prosecutor Carl. L. Ristine, the allegations of corruption by Lewis and Black were never investigated. The original air mail contracts were instead voided on the basis that they were illegally bid, without revealing what evidence was gathered on which that judgment was made and disregarding that most were obtained by the lowest bidder with the rest through statutory provisions of the Air Mail Act of 1930. The Air Mail Act of 1934 repealed those provisions but, with one exception, the carriers charged with illegally securing contracts under them were permitted to reacquire them despite provisions in the new act forbidding it. With bidding for contracts more competitive and air mail revenue less attractive than before, the airlines placed a new emphasis on passenger transportation and development of modern airliners. Several sued the government for revenues missed while the Air Corps flew the mail. The Black-McKellar bill sought to marginalize the suits by prohibiting the government from doing business with any carrier that filed them, but after severe criticism the provision was dropped from the bill. On February 4, 1935, almost a year after the contracts were cancelled, the District of Columbia Court of Appeals ruled that the cancellations "amounted to a breach of contract" and a taking of property without due process. The suits went forward, with the last claim settled in 1942. On July 14, 1941, Commissioner Richard H. Akers of the United States Court of Claims found that there had not been any fraud or collusion in the awarding of contracts pursuant to the Air Mail Act of 1930. Roosevelt also appointed Clark Howell, newspaper editor of the Atlanta Constitution, to chair a five-person committee to investigate all aspects of U.S. civil aviation, resulting in the creation of the Federal Aviation Commission. In severe economic distress, the airlines organized themselves in 1936 into the Air Transport Association of America. Two years later Black-McKellar went the way of McNary-Watres with the passage of the Civil Aeronautics Act, restructuring the airline industry to stress the features championed by Brown in 1930: "government-corporate linkages, limited competition, and restricted entry to the industry." The Air Line Pilots Association, a union that had publicly