[1] The case, along with Smith v. Maryland, established the principle of the third-party doctrine in relation to privacy rights.

The financial records supported evidence that Miller had rented the truck, radio equipment, and sheet metal to support the distillery, and he and four others were charged with conspiracy (by selling tax-free whiskey), possession of distilled spirits, and possession of an unregistered still.

Miller had attempted to argue that the Bank Secrecy Act, which required banks to make microfilm copies of all checks they processed, was unconstitutional, the Fifth Circuit recognized that the Supreme Court had validated the Act's constitutionality through California Bankers Ass'n v. Shultz,[2] but this did not allow for the types of actions that the ATF used.

The Fifth Circuit cited Boyd v. United States for the proposition that "a compulsory production of a man's private papers to establish a criminal charge against him...is within the scope of the Fourth Amendment".

[4] The government petitioned the Supreme Court to hear their appeal, asking whether the privacy rights of the Fourth Amendment covered the method that the ATF had acquired the bank records.