Hulsey v. Mnuchin
- Phyllis Hamilton
- 4:21-cv-02280
- U.S. District Court · Northern District of California
- 6
In Hulsey v. Mnuchin, Judge Hamilton dismissed Hulsey’s pro se lawsuit seeking an economic-impact payment, ruling that he stated no claim and could not receive CARES Act funds.
James Skip Hulsey; the order also explains the limits on individual relief available to members of the earlier class action involving incarcerated people and economic-impact payments.
What happened
In Hulsey v. Mnuchin, James Skip Hulsey, a Texas state prisoner representing himself, sued Steven Mnuchin over his failure to receive an economic-impact payment under the Coronavirus Aid, Relief, and Economic Security Act.
The court said Hulsey was already part of an earlier class action involving incarcerated people and payments denied because of incarceration, so he could not seek separate individual relief in this case. The earlier case also did not establish that every incarcerated person was owed a payment. The court further said the payment deadline had passed and the Internal Revenue Service was not in contempt merely because it had not sent Hulsey a payment.
The court dismissed the complaint without allowing an amended complaint and dismissed the action with prejudice. Judge Phyllis J. Hamilton ordered the clerk to close the case.
The detailed version
- Hulsey v. Mnuchin · No. 4:21-cv-02280
- Phyllis Hamilton
- Apr. 21, 2021
Background
James Skip Hulsey, identified as a state prisoner in Texas, brought a civil action without a lawyer against Steven Mnuchin. Hulsey sought court intervention concerning an economic-impact payment under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). He alleged that he had not received the payment and asked the court to require the Internal Revenue Service (IRS) to provide it and to hold the IRS in contempt.
Earlier Class Action
The court explained that an earlier class action had certified a class that included people who met specified requirements and were or had been incarcerated. Hulsey was part of that class. The earlier court had ruled that the CARES Act did not allow the government to withhold payments solely because a person was incarcerated and had ordered the government to reconsider payments denied solely for that reason.
That earlier court had expressly taken no position on whether any particular class member was actually owed a payment or on the amount of any payment. The responsibility for making that individual determination remained with the IRS.
Court’s Analysis
The court applied the prisoner-screening requirement in 28 U.S.C. § 1915A. That statute requires a federal court to identify claims that can proceed and dismiss claims that are frivolous, malicious, fail to state a claim, or seek money from an immune defendant. The court also noted that pleadings filed without a lawyer are read liberally, but they still must contain enough factual matter to make a claim legally plausible.
To the extent Hulsey argued that his payment was denied because of his incarceration, the court held that he was not entitled to separate individual relief because his allegations and requested relief duplicated the earlier class action. The court stated that class members must pursue further action through the class representatives and attorneys, including contempt proceedings or intervention in the class action.
To the extent Hulsey sought an order requiring the IRS to provide his payment under the earlier case or the CARES Act, the court held that the earlier case did not establish his individual entitlement to a payment. The court also held that the IRS was not in contempt merely for failing to send him a payment. In addition, the court stated that the CARES Act deadline of December 31, 2020, for payments to be made or allowed had passed, so no more funds could be issued under that Act.
Disposition
The court concluded that Hulsey 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 action was dismissed with prejudice, and the clerk was ordered to close the case.
Judge Phyllis J. Hamilton signed the order on April 21, 2021.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.