The following excerpt is from U.S. v. Cella, 568 F.2d 1266 (9th Cir. 1977):
Finally, the adoption of a target doctrine would lead to confusing and useless results as the fact that one is the target or object of a search does not mean that one's privacy will be invaded. For example, while investigating a suspect, government agents may decide to search his bank records. Although the suspect is clearly the target of the search, he would not have standing to suppress such evidence, as a bank depositor does not have a protectable Fourth Amendment interest in the bank's records of his account. Cf., United States v. Miller, 425 U.S. 435, 442-443, 96 S.Ct. 1619, 48 L.Ed.2d 71 (1976). The confusion arises from interpreting the phrase "one against whom the search was directed" to mean one whom the agents intend to use the evidence against rather than one who actually suffers the intrusion of the search and seizure by being the actual victim of the invasion of privacy.
III. A. 3. Standing of the defendants.
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