Recent federal legislation accords privacy protection to individuals concerning information held and compiled by third parties. States have also recognized the need to protect a person's privacy interest in information no longer in his exclusive control or possession. This legislation, however, is aimed only at limited kinds of privacy problems. It does not represent a comprehensive solution to the modern privacy dilemma: Does an individual have a legitimate privacy claim to information held by third parties? A critical advantage in analyzing the Miller decision is derived from tracing the development of privacy rights. Such a background may be used as a reference to determine whether Miller represents an enduring and positive contribution to the law of privacy.
Francis X. Pray,
A Bank Customer Has No Reasonable Expectation of Privacy of Bank Records: United States v. Miller,
San Diego L. Rev.
Available at: https://digital.sandiego.edu/sdlr/vol14/iss2/5