Planned Parenthood is not a bank: closing the clinic doors to the Fourth Amendment third party doctrine.

On May 30, 2002, investigators in Storm Lake, Iowa found a dead baby at a recycling center. The four-day-old boy had been run through a shredding device. In search of more information to assist in investigating the crime, the county attorney subpoenaed records from the Planned Parenthood of Greater Iowa, a women’s clinic, seeking the names of women receiving pregnancy tests from August 2001 to May 2002 at the organization. Other clinics and a local hospital cooperated with police and provided this information, but Planned Parenthood refused, calling the subpoena a “horrible assault to a young woman’s sense of privacy.” Buena Vista County District Judge Frank B. Nelson twice ordered the clinic to turn over the records, but the State Supreme Court stayed enforcement of the subpoena and scheduled a hearing for Planned Parenthood’s appeal in December 2002. Prosecutors in Buena Vista County argued that the Iowa statute governing physicianpatient privilege applies only to oral testimony in court. They also