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United States v. Richardson

Brief Fact Summary. Richardson, the Plaintiff-Respondent (Plaintiff) sued Congress. He alleged that public reporting under the Central Intelligence Agency (“CIA”) Act of 1949 violates Article I, s 9, cl. 7 (the Act) of the United States Constitution (Constitution), the statement and account clause.

Synopsis of Rule of Law. Standing is denied to “generalized grievances.”

Facts. Plaintiff sued Congress, hoping to compel release of detailed funding records of CIA funding. Plaintiff based his standing to sue on his status as a United States taxpayer.

Issue. Is taxpayer status sufficient to establish standing to bring suit in this case?

Held. No. Appeals court ruling reversed and remanded.
The Supreme Court of the United States (Supreme Court) applied the two-prong test developed in