Mattox v. IRS

Background

Timothy Mattox, identified as a state prisoner in Texas, brought this civil action against the IRS without a lawyer. He sought court intervention to obtain economic impact payments under the Coronavirus Aid, Relief, and Economic Security Act, commonly called the CARES Act. He stated that he had not received his payments.

The court explained that the CARES Act created a tax credit for eligible individuals and authorized advance payments of that credit. The Act also provided that no payment or credit could be made or allowed under the relevant provision after December 31, 2020.

The opinion discussed an earlier related class action, Scholl, concerning incarcerated people and the IRS policy of treating incarceration as a reason to deny economic impact payments. That class action resulted in a declaration that the CARES Act did not authorize withholding payments from class members solely because they were or had been incarcerated. The earlier court ordered the IRS to reconsider payments denied solely on that basis. It did not decide whether any particular class member was actually owed a payment or the amount of any payment.

Court’s Analysis

The court found that Mattox was a member of the Scholl class. To the extent his claim was based on denial of a payment solely because of his incarceration, the court held that he was not entitled to separate individual injunctive or equitable relief duplicating the class action. The opinion stated that class members could pursue further action through the class representatives and attorneys, including contempt proceedings or intervention in the class case.

The court separately rejected Mattox’s request to compel the IRS to provide his payments under the Scholl decision or the CARES Act. The Scholl decision required individual determinations by the IRS; it did not establish that every incarcerated person was owed a payment. In addition, the December 31, 2020 statutory deadline had passed, and the court stated that no more funds could be issued under the CARES Act. The court therefore concluded that Mattox could not obtain the relief he requested.

Disposition

The court concluded that Mattox 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 action was dismissed with prejudice. The court also vacated Mattox’s motion to proceed without paying filing fees because that motion had already been granted, and directed the clerk to close the case. Judge Phyllis J. Hamilton signed the order.