For our previous commentaries, see May 2003, August 2003, and October 2005. 2. 50 U.S.C. 1861 (a part of the Foreign Intelligence Surveillance Act), as amended by USA PATRIOT Act 215. 3. 50 U.S.C. 1861 requires that 215 orders be approved by a secret FISA court. FISA courts were created by 50 U.S.C. 1803. which authorizes the Chief Justice to appoint eleven FISA court judges, who serve for a maximum of seven years. 4.