Chris Hoofnagle, a San Francisco-based lawyer for the Electronic Privacy Information Center, a group focused on privacy issues, said the lack of widespread licensing standards for private investigators was a problem, noting that six states do not require licenses.

One of those states, Colorado, was the site of the first Federal Trade Commission lawsuit against a private detective for "pretexting," using deception to gain information. James J. Rapp and Ragena L. Rapp, whose Denver-area business obtained bank and phone records through various techniques, paid the government a $200,000 settlement in 2000. James Rapp also served a 75-day sentence for racketeering.

Rapp drew the attention of authorities when the LAPD suspected his firm of selling home addresses and phone numbers of organized-crime detectives to a reputed mobster.

California’s licensing requirements are among the most stringent, requiring three years of paid work experience for an investigative agency such as a police department or insurance company, passing a written exam and undergoing a criminal background check.

Yet Pellicano’s alleged transgressions occurred while he was a licensed investigator. He obtained his license in 1983; it expired in 2004, while he served prison time for possessing hand grenades and plastic explosives.

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