United States v. Richardson case brief

United States v. Richardson case brief summary

418 U.S. 166 (1974)

CASE SYNOPSIS

Petitioner United States sought certiorari review of an order from the United States Court of Appeals for the Third Circuit, which found respondent taxpayer demonstrated standing to challenge the constitutionality of the Central Intelligence Agency Act of 1949, 50 U.S.C.S. § 403a et seq.

CASE FACTS
Respondent taxpayer attempted to obtain information from petitioner Government regarding detailed expenditures of the Central Intelligence Agency (CIA) . Respondent sought a declaration that the Central Intelligence Agency Act of 1949 (CIAA), 50 U.S.C.S. § 403a et seq., was unconstitutional because the CIAA violated the federal Constitution's requirement to report federal spending.

PROCEDURAL HISTORY
The trial court granted a dismissal motion on the ground respondent lacked standing and that the issue was a political question. On appeal, the lower appellate court reversed, holding respondent met the two-tiered test for standing requiring a logical link between respondent's status as a taxpayer and the statute, as well as a nexus between respondent's status and a limitation on the taxing and spending power.

DISCUSSION

• On the Government's petition for certiorari review, the United States Supreme Court reversed, holding that respondent had failed to allege a direct injury and failed to challenge the taxing or spending power, thus, respondent had no standing. Respondent failed to show he suffered an injury different from that suffered by the public in general.

CONCLUSION

The Court reversed the lower appellate court's judgment finding respondent had standing to challenge a federal agency's expenditure reporting methods because respondent failed to allege a direct, personal injury that was different from that suffered by the general public.