What is the test for obtaining a wiretap warrant?

Driskel's primary argument is that the affidavit in support of the warrant application did not establish that traditional investigative techniques would be ineffective, and thus that the district court improperly granted the request for a wiretap warrant. Driskel fails to overcome two big hurdles, however: First, the so-called "necessity requirement" does not require that every other investigative method be completely inadequate and that a wiretap be the only means of effectuating the investigation. Rather, the "necessity requirement means that the affidavit must set out a factual background that shows that ordinary investigative procedures, employed in good faith, would likely be ineffective in the particular case." United States v. Brone, 792 F2d 1504, 1506 (9th Cir 1986). The second hurdle is the standard of review: We will reverse a district court's determination of necessity only upon a showing of abuse of discretion. United States v. Commito, 918 F2d 95, 98 (9th Cir 1990), cert denied, 112 SCt 224 (1991).