Stevens v. Internal Revenue Service
- Phyllis Hamilton
- 4:21-cv-00573
- U.S. District Court · Northern District of California
- 6
Stevens v. Internal Revenue Service: Judge Hamilton dismissed Stevens’s pro se CARES Act payment case with prejudice because the class action and deadline barred relief.
Andre Lafayette Stevens’s individual request for an economic impact payment was dismissed; the opinion does not determine whether he was otherwise eligible for or owed a payment.
What happened
In Andre Lafayette Stevens v. Internal Revenue Service, Stevens, a state prisoner representing himself, asked the court to help him obtain an economic impact payment under the CARES Act.
The court said Stevens was already part of a class action addressing payments denied solely because people were incarcerated, so he could not seek separate individual relief on that basis. The court also said the CARES Act’s December 31, 2020 deadline had passed, meaning the payment could no longer be issued in this case.
Judge Hamilton ruled that Stevens failed to state a claim, dismissed the action with prejudice, and ordered the case closed. The court also dismissed it without leave to amend.
The detailed version
- Stevens v. Internal Revenue Service · No. 4:21-cv-00573
- Phyllis Hamilton
- Mar. 4, 2021
Background
Andre Lafayette Stevens, a state prisoner proceeding without a lawyer, brought a civil action against the Internal Revenue Service and other defendants. He had been allowed to proceed without paying the filing fee. Stevens alleged that he submitted paperwork to obtain an economic impact payment under the Coronavirus Aid, Relief, and Economic Security Act, but had not received the payment. He asked the court to investigate and have the payment sent to him.
Screening standard
Because Stevens was a prisoner suing a governmental entity, the court screened the complaint under 28 U.S.C. § 1915A. That statute requires dismissal of claims that are frivolous, malicious, fail to state a claim for relief, or seek money from a defendant protected from that type of relief. The court also applied the rule requiring a complaint to provide enough factual information to make a plausible claim.
Reasons for dismissal
The court discussed an earlier class action concerning economic impact payments for incarcerated people. In that case, the court held that the CARES Act did not allow the defendants to withhold payments solely because a person was or had been incarcerated, and that the policy treating incarcerated people as ineligible on that basis was unlawful. The earlier case did not decide whether any particular person was actually owed a payment or how much that person should receive; those decisions were left to the Internal Revenue Service.
The court found that Stevens was a member of that class. To the extent he claimed that his payment was denied solely because of his incarceration, the court held that he was not entitled to separate individual injunctive or equitable relief because his claim duplicated the existing class action. The court further held that Stevens could not use this case to compel payment under the earlier class-action decision or the CARES Act. The Act required payments to be made or allowed by December 31, 2020, and that deadline had passed. The court therefore concluded that Stevens could not obtain the relief he requested.
Disposition
The court ruled that Stevens failed to state a claim for relief. It dismissed the complaint without leave to amend because it found that no amendment could cure the identified problems. In the conclusion, the court stated: “The action is DISMISSED with prejudice,” and directed the clerk to close the case.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.