Wilson v. Department of Treasury

Background

Kenneth Wilson, identified as a state prisoner in Indiana, brought a civil action without a lawyer against a governmental entity. He had been allowed to proceed without paying the filing fee. Wilson sought court intervention to obtain an economic impact payment under the Coronavirus Aid, Relief, and Economic Security Act, commonly called the CARES Act.

The court explained that the CARES Act created a tax credit for eligible individuals and authorized advance payments of that credit. The statute provided that no refund or credit could be made or allowed under the advance-payment provision after December 31, 2020.

Related Class Action

The court discussed an earlier related class action, Scholl v. Mnuchin. In that case, the court certified a class that included qualifying United States citizens and legal permanent residents who were or had been incarcerated and declared that the CARES Act did not allow the government to withhold advance payments solely because a person was incarcerated. The earlier court ordered the government to reconsider payments denied solely on that basis.

The earlier court did not decide whether any particular class member was actually owed a payment or the amount of any payment. Instead, the Internal Revenue Service was responsible for making individual eligibility determinations.

Reasoning

The court stated that Wilson was incarcerated and part of the Scholl class. To the extent he claimed that his payment had been denied because of his incarceration, the court held that he was not entitled to separate individual injunctive or equitable relief duplicating the class action. The court said class members must pursue additional actions through the class representatives and attorneys, including contempt proceedings or intervention in the class action.

The court also rejected Wilson’s request to compel payment under the Scholl decision or the CARES Act. The earlier decision barred denial based only on incarceration, but it did not establish that every incarcerated person was owed a payment. In addition, the court concluded that the December 31, 2020 statutory deadline had passed and that no additional funds could be issued under the CARES Act.

Disposition

After screening the complaint under 28 U.S.C. § 1915A, the court found that Wilson failed to state a claim for relief. It dismissed the complaint without leave to amend because the deficiencies could not be cured by amendment. The conclusion states: “The action is DISMISSED with prejudice.” The clerk was directed to close the case. Judge Phyllis J. Hamilton signed the order.