Engrum v. IRS

Background

Jeffery C. Engrum, a state prisoner proceeding without a lawyer, brought a civil action against the IRS and others. He had permission to proceed without paying the filing fee. Engrum sought court intervention to obtain an economic impact payment under the Coronavirus Aid, Relief, and Economic Security Act, commonly called the CARES Act. He said he had sent paperwork to the IRS but had not received the payment.

Screening standard

Because Engrum was a prisoner suing a governmental entity, the court screened the complaint under 28 U.S.C. § 1915A. That law requires dismissal of claims that are frivolous, malicious, fail to state a legally sufficient claim, or seek money from a defendant protected from such relief. The court also explained that complaints filed without a lawyer are read liberally, but they still must include enough factual allegations to make the requested relief plausible.

Analysis

The court relied on the earlier class action Scholl v. Mnuchin. In that case, the court ruled that the CARES Act did not allow the government to deny advance refunds or credits solely because a person was or had been incarcerated. The class action included people meeting specified requirements who were incarcerated or had been held to have violated parole or probation conditions.

The court concluded that Engrum was a member of the Scholl class. To the extent he claimed that the IRS denied his payment solely because he was incarcerated, the court said he was not entitled to separate individual relief because that claim duplicated the class action. The court explained that class members seeking further equitable or declaratory relief must pursue it through the class action, including through the class representative and attorney, contempt proceedings, or intervention.

The court separately rejected Engrum’s request to compel payment under the Scholl ruling or the CARES Act. Scholl established only that incarceration could not be the sole reason for denying a payment; it did not decide whether any particular incarcerated person was otherwise eligible or owed a payment. Those individual eligibility decisions belonged to the IRS. In addition, the CARES Act stated that no payment could be made or allowed after December 31, 2020, and the court held that the deadline had passed.

Disposition

The court held that Engrum failed to state a claim for relief. It dismissed the complaint without leave to amend because it was clear that no amendment could cure the identified problems. The action was dismissed with prejudice, and the clerk was ordered to close the case. Judge Phyllis J. Hamilton signed the order on May 17, 2021.