Coy v. Trump

Background

Braidan C. Coy, a state prisoner in Indiana, brought this civil action without a lawyer against a governmental entity. He had already been allowed to proceed without paying the filing fee. Coy sought money damages because he had not received an economic impact payment under the Coronavirus Aid, Relief, and Economic Security Act, commonly called the CARES Act.

Screening standard

Because Coy was a prisoner suing a governmental entity, the court was required to screen the complaint under 28 U.S.C. § 1915A. The court had to identify claims that could proceed and dismiss claims that were frivolous, malicious, failed to state a claim, or sought money from an immune defendant. The court also applied the requirement that a complaint provide enough factual matter to make the requested relief plausible, rather than relying only on labels or legal conclusions.

Existing class action

The court discussed an earlier related class action concerning economic impact payments for people who were or had been incarcerated. In that case, the court had ruled that the CARES Act did not permit the government to withhold payments solely because a person was incarcerated. It had ordered the government to reconsider payments denied solely for that reason.

But the earlier case did not decide whether any particular incarcerated person was actually entitled to a payment or the amount of any payment. Those individual eligibility decisions were left to the Internal Revenue Service. The earlier class action also did not provide individualized money damages.

Court’s analysis

The court stated that Coy was a member of the earlier class. To the extent he challenged denial of a payment solely because of his incarceration, he could not obtain separate individual relief through a duplicative lawsuit.

The court also rejected any request to compel the Internal Revenue Service to provide Coy with a payment under the earlier case or the CARES Act. The CARES Act required payments or credits to be made or allowed by December 31, 2020, and that deadline had passed by the time of this case. The court therefore concluded that Coy could not obtain the relief he sought. In addition, the court noted that Coy had not shown that the CARES Act created a private right of action allowing him to seek damages for the failure to issue a payment.

Disposition

The court held that Coy 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. The court’s order states: “The action is DISMISSED with prejudice.” The clerk was directed to close the case.