Scott v. Yellen

Background

Donnie Scott, a state prisoner proceeding without a lawyer, brought a civil action against a governmental entity and other defendants. He had permission to proceed without paying the filing fee. Scott sought court intervention to obtain an economic impact payment under the Coronavirus Aid, Relief, and Economic Security Act, commonly called the CARES Act. He stated that he had not received the payment.

Screening and Related Class Action

Because Scott was a prisoner seeking relief from 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, or seek money from an immune defendant. The court also explained that complaints filed without a lawyer are read liberally but still must contain enough factual allegations to state a plausible claim.

The court discussed a prior related class action concerning economic impact payments for incarcerated people. In that case, the court declared that the CARES Act did not allow the defendants to withhold payments solely because a person was or had been incarcerated. It also declared that the policy treating people incarcerated during 2020 as ineligible was unlawful and required the defendants to reconsider payments denied solely for that reason.

The earlier court, however, had not decided whether any particular incarcerated person was actually owed a payment or how much that person should receive. Those individual eligibility decisions were left to the Internal Revenue Service. Scott was a member of that class.

Court’s Analysis

The court held that Scott could not obtain separate injunctive or equitable relief based on denial of a payment solely because of incarceration. Those allegations and requested remedies duplicated the existing class action, and class members had to pursue further action through the class representatives and attorneys or seek intervention in that case.

The court also rejected Scott’s request to compel payment under the earlier class action or the CARES Act. The CARES Act required payments to be made or allowed by December 31, 2020. Because that deadline had passed, the court concluded that funds could no longer be distributed under the Act and that Scott could not obtain the relief requested in this case.

Disposition

The court concluded that Scott 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 deficiencies. The order states: “The action is DISMISSED with prejudice and all pending motions are DENIED.” The clerk was ordered to close the case.

Classification

This is a procedural order because the court dismissed the complaint during prisoner screening for failure to state a claim, rather than deciding whether Scott was substantively entitled to an individual economic impact payment.