Aruanno v. Internal Revenue Service

Background

Joseph Aruanno, described by the court as a civilly committed detainee in New Jersey, filed a civil action without a lawyer against the Internal Revenue Service. He sought court intervention to obtain an additional economic impact payment under the Coronavirus Aid, Relief, and Economic Security Act. The court had granted his motion to proceed in forma pauperis, meaning he could proceed without prepaying the filing fee.

Screening standard

Because the action sought relief from a governmental entity, the court applied the preliminary screening required by 28 U.S.C. § 1915A. Under that statute, the court must identify claims that can proceed and dismiss claims that are frivolous, malicious, fail to state a claim, or seek money from an immune defendant. The court also applied the rule that pleadings filed without a lawyer are read liberally, while requiring enough factual allegations to make a claim plausible rather than merely speculative.

Economic impact payment claim

The court reviewed an earlier class action concerning economic impact payments and the Internal Revenue Service’s policy of treating incarcerated people as ineligible. That earlier ruling declared that the statute did not permit withholding payments solely because a person was or had been incarcerated. But the earlier court expressly did not decide whether any particular person was owed a payment or how much that person should receive; those determinations were left to the Internal Revenue Service.

The court further noted that the Coronavirus Aid, Relief, and Economic Security Act required payments to be made or allowed no later than December 31, 2020. Because that deadline had passed, the court concluded that additional funds could not be distributed under the Act. Aruanno therefore could not obtain the requested relief, and the complaint failed to state a claim.

Disposition

Judge Phyllis J. Hamilton granted the motion to proceed in forma pauperis. 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 also stated that, to the extent Aruanno claimed officials at his New Jersey facility stole his payment, he may seek relief in the District of New Jersey against those defendants.