Chao v. Community Trust Co.

474 F.3d 75 (2007)

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Chao v. Community Trust Co.

United States Court of Appeals for the Third Circuit
474 F.3d 75 (2007)

Facts

The secretary of labor (the government) (plaintiff) began an investigation into certain financial improprieties of an employee welfare benefit trust. As a part of the investigation, the secretary of labor issued a subpoena to the Community Trust Company (CTC) (defendant). The CTC maintained an account for the trust that was being investigated. The CTC claimed that the subpoena required disclosure of documents that were personal financial records. The CTC argued that disclosing such information would violate the privacy rights of its customers in violation of (as relevant here) the Right to Financial Privacy Act (RFPA). The CTC argued that the investigation was beyond the government’s authority and that the CTC was therefore forbidden by the RFPA from disclosing the subpoenaed information. The district court disagreed and concluded that the RFPA was inapplicable. Specifically, the district court reasoned that there were no customers involved in the subpoena. Under the RFPA, customers included small partnerships and individuals, not large trusts. The district court therefore concluded that the RFPA’s protections did not apply. The CTC appealed.

Rule of Law

Issue

Holding and Reasoning (Roth, J.)

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