Sharp v. Koskinen

Background

Anthony A. Sharp, a state prisoner proceeding without a lawyer, brought a civil action against a governmental entity and was allowed to proceed without paying the filing fee. He sought court intervention to obtain an economic impact payment under the Coronavirus Aid, Relief, and Economic Security Act, commonly called the CARES Act. Sharp stated that he had sent his paperwork to the Internal Revenue Service but had not received the payment.

The opinion discussed an earlier class action concerning incarcerated people and CARES Act payments. In that earlier proceeding, the court declared that the CARES Act did not allow the defendants to withhold payments solely because a person was or had been incarcerated. The earlier court also ordered the defendants to reconsider payments denied solely for that reason. But it expressly did not decide whether any particular person was actually owed a payment or the amount of any payment.

Screening analysis

Because Sharp was a prisoner seeking relief from a governmental entity, the court was required to screen his complaint under 28 U.S.C. § 1915A. Screening requires dismissal of claims that are frivolous, malicious, fail to state a claim for relief, or seek money from a defendant immune from that relief. The court also applied the requirement that a complaint contain enough factual matter to state a plausible claim.

The court found that, to the extent Sharp claimed his payment was denied because of his incarceration, he was already a member of the earlier class. He therefore was not entitled to separate individual injunctive or equitable relief duplicating the class action. The court explained that any further action concerning the class’s relief had to proceed through the class action’s representatives and attorneys, including through procedures identified in that case.

The court separately rejected Sharp’s request to compel the IRS to provide him a payment under the earlier class action or the CARES Act. The earlier class action only prohibited denial based solely on incarceration; it did not determine whether Sharp met all individual eligibility requirements. The court also held that the CARES Act deadline of December 31, 2020, for payments to be made or allowed had passed, so the requested payment could not be issued under that Act.

Disposition

The court concluded that Sharp failed to state a claim for relief. It dismissed the complaint without leave to amend because it found that no amendment could cure the deficiencies. The action was dismissed with prejudice, and the clerk was ordered to close the case. Judge Phyllis J. Hamilton signed the order.