Monday v. Department of Treasury

Background

Jimmie Joe Monday, a state prisoner in Indiana, brought this civil action without a lawyer against the Department of Treasury and other defendants. He had permission to proceed without paying the filing fee. Monday 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.

The court screened the complaint under 28 U.S.C. § 1915A, which requires courts to review prisoner lawsuits against governmental entities and dismiss claims that are frivolous, fail to state a claim, or seek money from an immune defendant.

Prior class action

The court relied on an earlier related class action in the Northern District of California. That class included qualifying United States citizens and lawful permanent residents who were or had been incarcerated and otherwise met the CARES Act’s requirements. The earlier court declared that the CARES Act did not allow the government to withhold economic impact payments solely because a person was incarcerated. It also found that the policy treating people incarcerated during 2020 as ineligible was arbitrary, capricious, and unlawful, and ordered the government to reconsider payments denied solely on that basis.

The earlier court did not decide whether any particular incarcerated person was actually owed a payment or how much that person should receive. Instead, the Internal Revenue Service was responsible for making individual eligibility determinations.

Court’s reasoning

The court determined that Monday was part of the earlier class. To the extent he claimed that his payment had been denied because he was incarcerated, the court held that he was not entitled to separate individual relief because his request duplicated the existing class action. The court explained that class members must pursue additional equitable or declaratory relief through the class action, including through the class representatives and attorneys or by intervening in that action.

The court separately rejected Monday’s request to compel payment under the earlier class-action ruling or the CARES Act. The earlier ruling established only that incarceration alone could not justify denying a payment; it did not establish that Monday was individually entitled to one. In addition, the CARES Act stated that no refund or credit could be made or allowed after December 31, 2020. Because that deadline had passed, the court concluded that Monday could not obtain the requested relief in this case.

Disposition

The court concluded that Monday 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. In the conclusion, the court ordered that the action be dismissed with prejudice and directed the clerk to close the case. Judge Phyllis J. Hamilton signed the order.