Padilla v. Internal Revenue Service
- Phyllis Hamilton
- 4:24-cv-02982
- U.S. District Court · Northern District of California
- 2
In Padilla v. Internal Revenue Service, Judge Hamilton denied the plaintiff’s reconsideration motion because he repeated earlier arguments and the payment deadline had passed.
Ismael H. Padilla and the Internal Revenue Service; the ruling denied Padilla’s request for relief from the earlier screening ruling and did not provide an economic impact payment.
What happened
In Padilla v. Internal Revenue Service, Ismael H. Padilla, a Texas state prisoner representing himself, asked the court to help obtain an economic impact payment under the CARES Act. The court had previously denied the case at screening.
The court treated Padilla’s reconsideration request as a motion for relief from judgment under Rule 60(b). It denied the motion because Padilla repeated his earlier arguments, presented no newly discovered evidence, and showed no other basis for relief. The court also explained that the deadline for issuing CARES Act payments had passed, so no more funds could be distributed under that law.
Judge Phyllis J. Hamilton denied Padilla’s motion for reconsideration. The ruling did not award him an economic impact payment.
The detailed version
- Padilla v. Internal Revenue Service · No. 4:24-cv-02982
- Phyllis Hamilton
- Aug. 14, 2024
Background
Ismael H. Padilla, a Texas state prisoner proceeding without a lawyer, filed a civil action against the Internal Revenue Service and other defendants seeking court intervention to obtain an economic impact payment under the Coronavirus Aid, Relief, and Economic Security Act, commonly called the CARES Act. The court had denied the case at screening. Padilla then filed a motion for reconsideration.
Legal standard
The court construed the motion as a request for relief from judgment under Federal Rule of Civil Procedure 60(b). That rule permits relief on specified grounds, including mistake, newly discovered evidence, fraud, a void judgment, satisfaction of the judgment, or another reason justifying relief. Motions under the first three grounds must be filed no later than one year after entry of judgment; other Rule 60(b) motions must be filed within a reasonable time.
Court’s reasoning
The court explained that Padilla had been advised that the court could not compel the IRS to provide the payment. The court discussed an earlier case in which the court held that an economic impact payment could not be denied solely because a person was incarcerated, but that decision did not determine whether any particular incarcerated person was owed a payment. The IRS was responsible for making that individual determination.
The court further held that funds could no longer be distributed under the CARES Act because the Act required the payments to be made or allowed by December 31, 2020, and that deadline had passed. In addition, Padilla repeated the arguments from his complaint and did not present newly discovered evidence or demonstrate another ground for relief under Rule 60(b).
Disposition
Judge Phyllis J. Hamilton DENIED Padilla’s motion for reconsideration, identified as Docket No. 10.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.