SPA Flying Service, Inc. v. United States

Spa Flying Service, Inc. (“Spa”) appeals from dismissal with prejudice of its complaint for failure to state a claim under Fed.R.Civ.P. 12(b)(6). The Federal Aviation Administration had subpoenaed Spa’s financial records from its bank. Suing under the Right to Financial Privacy Act of 1978, 12 U.S.C. § 3401 et seq., Spa claimed protection from such governmental intrusion. The district court found, however, that the Act does not protect corporations. The single issue stated on appeal is whether the Act applies to corporations. We affirm.

The Act requires that before financial institutions…