Facts
- Congress enacted the Central Intelligence Agency Act of 1949, permitting CIA expenditures to be accounted for solely by the CIA Director’s certificate and exempting them from ordinary public reporting requirements.
- A federal taxpayer sued federal officials, alleging the Act violated the Statement and Account Clause of Article I, § 9, cl. 7, which requires publication of a regular statement and account of receipts and expenditures of public money.
- The plaintiff claimed secrecy about CIA spending impaired his ability to act as an informed voter and sought declaratory and injunctive relief requiring more detailed public accounting.
- The district court dismissed for lack of standing.
- The Third Circuit reversed en banc, holding the plaintiff met the two-part taxpayer-standing test associated with Flast v. Cohen.
- The Supreme Court granted certiorari to review whether Article III standing existed.
Issues
- Whether a federal taxpayer has Article III standing to challenge statutes governing CIA accounting and reporting on the ground that they violate the Statement and Account Clause.
- Whether an asserted injury consisting of reduced access to information about government expenditures is sufficiently concrete and particularized, rather than a generalized grievance shared by the public.
Decision
- The Supreme Court reversed the Third Circuit.
- The Court held the plaintiff lacked Article III standing because the asserted injury was undifferentiated and common to all members of the public.
- The Court concluded the challenge was directed to agency accounting and reporting procedures, not the type of taxing-and-spending enactment that supports the narrow taxpayer-standing exception recognized in Flast.
- The Court indicated that complaints about the degree of disclosure for CIA expenditures must be pursued through the political process rather than federal courts.
Legal Principles
- Article III requires a plaintiff to show a concrete, particularized injury; broadly shared objections to government conduct generally do not establish standing.
- Federal taxpayer standing is limited; the Flast exception does not extend to challenges that lack a sufficient connection between taxpayer status and the specific exercise of Congress’s taxing and spending power.
- A claimed informational or voter-related injury tied to government secrecy about expenditures, without individualized harm, is a generalized grievance insufficient to invoke federal judicial power.
Conclusion
The Court held that a federal taxpayer could not sue to force greater public disclosure of CIA expenditures because the alleged harm was a generalized grievance and the suit fell outside the narrow limits of taxpayer standing under Article III.