United States v. Richardson Case Brief

Why is the case important?

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.

Facts of the case

Richardson, a taxpayer interested in activities of the Central Intelligence Agency, sued the government to provide records detailing the CIA’s expenditures.


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


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


The Supreme Court of the United States held that Richardson failed to allege a direct injury and failed to challenge the taxing or spending power, thus, he had no standing. Richardson failed to show he suffered an injury different from that suffered by the public in general.

  • Case Brief: 1974
  • Petitioner: United States
  • Respondent: Richardson
  • Decided by: Burger Court

Citation: 418 US 166 (1974)
Argued: Oct 10, 1973
Decided: Jun 25, 1974