Aruanno v. Internal Revenue Service
- Phyllis Hamilton
- 4:25-cv-03073
- U.S. District Court · Northern District of California
- 2
In Aruanno v. Internal Revenue Service, Judge Hamilton denied reconsideration, finding no Rule 60(b) basis and no CARES Act payments could issue.
Joseph Aruanno, the Internal Revenue Service, and Aruanno’s requests for appointed counsel or a guardian ad litem.
What happened
In Aruanno v. Internal Revenue Service, Joseph Aruanno, proceeding without a lawyer, asked the court to help obtain an economic impact payment under the CARES Act. The court had previously denied his case during screening.
The court treated Aruanno’s reconsideration request as a request for relief from judgment under Rule 60(b). It explained that he repeated his earlier arguments, presented no newly discovered evidence, and showed no other ground for relief. The court also said the deadline for issuing CARES Act payments had passed and that the IRS—not the court—was responsible for deciding whether an individual was owed a payment.
Judge Phyllis J. Hamilton denied the motion for reconsideration and also denied Aruanno’s requests for appointed counsel or a guardian ad litem. The court stated that he could seek relief in New Jersey against officials there if they were interfering with his payments.
The detailed version
- Aruanno v. Internal Revenue Service · No. 4:25-cv-03073
- Phyllis Hamilton
- July 21, 2025
Background
Joseph Aruanno, a civilly committed detainee in New Jersey proceeding without a lawyer, filed a civil action against the Internal Revenue Service. The court previously denied the case during screening. Aruanno then filed a motion for reconsideration.
Aruanno sought court intervention to obtain an economic impact payment under the Coronavirus Aid, Relief, and Economic Security Act, commonly called the CARES Act. The opinion refers to an earlier decision holding 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; that determination belonged to the Internal Revenue Service.
Rule 60(b) Analysis
The court construed the reconsideration motion as a motion for relief from judgment under Federal Rule of Civil Procedure 60(b). That rule permits relief on specified grounds, including mistake or excusable neglect, newly discovered evidence, fraud by the opposing party, a void judgment, satisfaction of the judgment, or another reason justifying relief. Motions based on the first three grounds must be filed within one year, and all Rule 60(b) motions must be filed within a reasonable time.
The court concluded that Aruanno repeated the arguments from his complaint. It found that he did not present newly discovered evidence or establish another ground for relief under Rule 60(b).
Economic Impact Payment Deadline
The court further stated that the CARES Act required economic impact payments to be made or allowed by December 31, 2020. Because that deadline had passed, the court said that no additional funds could be distributed under the CARES Act.
Ruling
The court denied Aruanno’s motion for reconsideration, identified as Docket No. 8. It also denied his requests for appointment of counsel or a guardian ad litem because the case was meritless. The court stated that, if officials in New Jersey were interfering with his economic impact payments, he could seek relief against those defendants in the District of New Jersey.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.