Padilla v. Internal Revenue Service

Background

Ismael H. Padilla, a Texas state prisoner proceeding without a lawyer, brought a civil action against the Internal Revenue Service and other defendants. He had permission to proceed without paying the filing fee. Padilla sought court intervention to obtain an economic impact payment under the Coronavirus Aid, Relief, and Economic Security Act, commonly called the CARES Act. He also sought an order requiring the Internal Revenue Service to stop denying payments solely because a person was incarcerated.

Screening standard

Because Padilla was a prisoner suing a governmental entity, the court was required to screen the complaint before the case proceeded. Under the prisoner-screening statute, the court had to identify claims that could proceed and dismiss claims that were frivolous, malicious, failed to state a legally sufficient claim, or sought money from a defendant protected from that relief. The court also applied the rule requiring a complaint to provide enough factual matter to make the requested relief plausible, while construing a self-represented party’s allegations liberally.

Economic impact payments

The court reviewed an earlier related class action concerning CARES Act economic impact payments and incarcerated people. That earlier decision held that the statute did not allow the defendants to withhold advance refunds or credits from class members solely because they were or had been incarcerated. It also held that a policy treating people incarcerated at any time in 2020 as ineligible was arbitrary, capricious, and unlawful. The earlier court entered an injunction requiring reconsideration of payments denied solely for that reason.

The earlier decision did not determine whether any particular person was owed a payment or the amount of any payment. Instead, it left the Internal Revenue Service responsible for making individual eligibility decisions. The CARES Act also provided that no payment could be issued or allowed after December 31, 2020. That deadline had passed by the time of Padilla’s case.

Ruling

The court concluded that Padilla was not entitled to the relief he requested. Although the earlier class action barred denial based solely on incarceration, it did not establish that Padilla personally was owed a payment. More importantly, the statutory deadline had passed, so the requested payment could no longer be issued under the CARES Act. The court therefore found that Padilla failed to state a claim for relief.

The action was dismissed without leave to amend, because the court found that no amendment could cure the identified deficiencies. The clerk was directed to close the case. The court added that any request for relief concerning Padilla’s confinement conditions or underlying conviction had to be brought in the appropriate district in Texas.