Sunday, January 13, 2019

United States v. Miller Case Brief: Fourth Amendment and the Third-Party Doctrine in Business Records

Case Brief: United States v. Miller

Court: Supreme Court of the United States
Citation: 425 U.S. 435 (1976)
Argued: November 9, 1975
Decided: March 2, 1976


Facts:

In United States v. Miller, the defendant Miller was suspected of being involved in a scheme to illegally distill and distribute whiskey. To gather evidence against him, the government subpoenaed records from Miller’s bank and accounting firm, specifically seeking bank statements and checks that Miller had written. The subpoenas were issued without Miller’s consent or a warrant.

Miller objected to the production of these records, arguing that his Fourth Amendment rights were violated because he had a reasonable expectation of privacy in the documents held by his bank and his accountant.

Issues:

  1. Whether the government violated Miller's Fourth Amendment rights by obtaining his bank records without his consent or a warrant.
  2. Whether there is an expectation of privacy in business records held by third parties (such as banks and accountants).

Holding:

The Supreme Court held in a 6-3 decision that Miller did not have a reasonable expectation of privacy in the bank records and accounting records held by third parties. The Court ruled that the documents Miller sought to protect were not entitled to Fourth Amendment protections because he had no expectation of privacy in information that was voluntarily disclosed to third parties.

Legal Reasoning:

  • No Expectation of Privacy in Third-Party Records: The Court, in an opinion written by Justice Powell, emphasized that the Fourth Amendment does not protect information voluntarily disclosed to third parties. In this case, Miller had provided his bank and accountant with access to the records, and thus, he had no reasonable expectation that the government could not obtain this information.

  • Third-Party Doctrine: The Court applied the "third-party doctrine," which holds that individuals cannot expect privacy in information they share with third parties, such as banks or accountants, even if they expect confidentiality. In this case, Miller had disclosed his financial records to banks and accountants, and these records were considered the property of the banks, not Miller’s.

  • Distinction from Private Papers: The Court also distinguished between business records and private papers. While the Fourth Amendment protects private papers, business records held by third parties are not protected in the same way. This was especially true in Miller’s case, where the information at issue was maintained by institutions with which he had business relationships.

  • No Constitutional Violation: Because the records were held by third parties, the Court concluded that the government’s action in subpoenaing these records did not constitute an unlawful search or seizure. Thus, the government was entitled to use these documents as evidence against Miller.

Dissenting Opinion:

  • Justice Brennan dissented, joined by Justices Marshall and Stewart, arguing that the majority’s reasoning would erode the privacy rights of individuals in their financial and personal matters. Brennan believed that bank records and similar documents should be protected under the Fourth Amendment, as they contain sensitive information about an individual's finances.

Conclusion:

The Supreme Court ruled that Miller had no reasonable expectation of privacy in his bank and accounting records because they were disclosed to third parties. Therefore, the government could subpoena these records without violating the Fourth Amendment. The decision reinforced the third-party doctrine, which holds that information voluntarily given to third parties is not protected by the Fourth Amendment.


List of Cases Cited:

  1. Katz v. United States, 389 U.S. 347 (1967) - Established the reasonable expectation of privacy test for Fourth Amendment protections.
  2. Smith v. Maryland, 442 U.S. 735 (1979) - Held that there is no expectation of privacy in the numbers dialed from a telephone, as they are exposed to the phone company.
  3. Warden v. Hayden, 387 U.S. 294 (1967) - Discussed the scope of the Fourth Amendment's protection for individuals’ privacy in their personal property.

Similar Cases:

  1. California v. Greenwood, 486 U.S. 35 (1988) - Held that there is no expectation of privacy in trash left outside for collection, as it is exposed to the public.
  2. United States v. Miller, 425 U.S. 435 (1976) - Established that individuals do not have an expectation of privacy in records held by third parties like banks or accountants.
  3. Smith v. Maryland, 442 U.S. 735 (1979) - Held that there is no reasonable expectation of privacy in telephone numbers dialed from a landline because such information is disclosed to third parties.

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