This article records tradition as it has been passed down and reported. Its sources are not yet part of the atlas's verified catalogue.
The auditing technique L. Ron Hubbard developed for Dianetics and carried into the Church of Scientology used a device he designed, the E-meter, as part of the counseling process. In 1971, that device itself became the subject of a federal court case, United States v. An Article or Device, after the FDA seized a number of Hubbard-designed E-meters.
The court's ruling drew a specific line rather than settling the matter in either direction outright: auditing with the E-meter could continue, but only for avowedly religious purposes, and any device used had to carry a disclaimer stating that it made no medical claim. The ruling neither endorsed auditing as medically effective nor banned its use outright, treating it instead as protected religious practice once separated from any claim to clinical treatment.
That 1971 ruling came fifteen years before Hubbard's own death in 1986, so it was decided while he was still alive and still directing the organization by written policy. It stands as the clearest official determination on record of how the auditing practice he founded would be treated under American law, drawing a boundary between religious counseling and medical device regulation that the organization has operated within since.