United States v. Richardson

418 U.S. 166 (1974)

Facts

Respondent Richardson (P), as a federal taxpayer, brought this suit for the purpose of obtaining a declaration of unconstitutionality of the Central Intelligence Agency Act, which permits the CIA to account for its expenditures 'solely on the certificate of the Director. . . .' P alleged this violated Art. I, § 9, cl. 7, of the Constitution insofar as that clause requires a regular statement and account of public funds. The District Court's dismissal of the complaint for respondent's lack of standing under Flast v. Cohen. This was reversed by the Court of Appeals. That court held that respondent had standing as a taxpayer on the ground that he satisfied Flast's requirements that the allegations (1) challenge an enactment under the Taxing and Spending Clause of Art I, § 8, and show (2) a 'nexus' between the plaintiff's status and a specific constitutional limitation on the taxing and spending power.