United States v. Miller: Summary

Instructor: Erin Krcatovich

Erin teaches undergraduate and graduate classes in Political Science, Public Policy, and Public Administration and has a PhD in Political Science.

United States v. Miller is a Supreme Court case from 1976 that involves the Fourth Amendment. In this lesson, we will learn about the concept of search and seizure and explore the Court's reasoning in this case.

Unreasonable Search and Seizure

United States v. Miller is a 1976 Supreme Court case that discusses the concept of unreasonable search and seizure in the context of whether your bank account records are private property or not.

The Fourth Amendment protects us against the police taking our property, particularly as evidence, without a properly issued warrant or unreasonable search and seizure. A warrant is an official court document, signed by a judge, which defines a particular area (such as a home or business) to be searched and the property that the police are allowed to look for. Unreasonable search and seizure means that the police are not allowed to search your home, car, or business unless they have a warrant issued by a judge, and they can't seize, or take anything, as evidence from that search unless it is identified in the warrant.

Within the process of searching, if other evidence is discovered in that same area, the police are within their rights to take that property as well. However, if a warrant is not issued or if the police search beyond the defined area, evidence collected can be inadmissible, or not allowed to be used as evidence in court.

There are some exceptions to the Fourth Amendment, such as when the police observe a crime in progress and need to intervene so they can collect evidence before it can be destroyed or damaged.

United States v. Miller Case Background

In this case, Miller was found guilty of illegally selling whiskey and conspiracy to defraud the government because he did not pay the government taxes on the sale.

He appealed his conviction, arguing that his bank records were illegally taken as evidence. During the investigation, the bank was subpoenaed (formally asked) to produce his bank account records. The bank employee produced the requested documents, making copies as asked. Thus, Miller was not told by a warrant issued by a judge to allow the bank to make copies of his records.

Miller's attorneys objected to the seizure because the subpoenas were not issued by a court but by the U.S. Attorney, and the date to return the documents was not when the grand jury was meeting, making it difficult to properly process them. Most importantly, though, Miller said he should have a right to expect that his bank account information was personal information that would be kept private and not shared with others outside of the bank.

Thus, this case asks the important constitutional question of if the collection of Miller's bank records violated his Fourth Amendment rights against unreasonable search and seizure.

Are Bank Records Private Property?

The Supreme Court reviewed Miller's claim that his conviction should be overturned on the grounds that his Fourth Amendment rights were violated. In a vote of 7 to 2, the Court held that the bank records were not seized illegally.

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