Keihl v. Internal Revenue Service

Background

Ronald Edward Keihl, identified in the opinion as a state prisoner in Maryland, filed this civil action without a lawyer against the Internal Revenue Service and others. He had permission to proceed without paying the filing fee. Keihl 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.

Screening standard

Because Keihl was a prisoner suing a governmental entity, the court screened the complaint under 28 U.S.C. § 1915A. That statute requires the court to identify claims that may proceed and dismiss claims that are frivolous, malicious, inadequately pleaded, or seek money from a defendant protected from that type of relief. The court also applied the requirement that a complaint provide enough factual information to make a plausible claim for relief.

Economic impact payments and the earlier class action

The opinion explained that the CARES Act created a tax credit and an advance refund, commonly referred to as an economic impact payment. The Act defined who could qualify and stated that no refund or credit could be made or allowed under the relevant advance-refund provision after December 31, 2020.

The court discussed an earlier related class action in which the court certified a class that included people who were or had been incarcerated and met specified citizenship, income, dependency, tax-filing, and Social Security number requirements. That court declared that the CARES Act did not permit the defendants to withhold advance refunds or credits solely because a person was or had been incarcerated. It also found the IRS’s incarceration-based policy arbitrary, capricious, and unlawful, entered a permanent injunction, and required reconsideration of payments denied solely on that basis.

The earlier court expressly did not decide whether particular plaintiffs or class members were owed payments or the amount of any payment. Instead, the IRS remained responsible for making individual eligibility determinations.

Court’s reasoning

The court found that Keihl was incarcerated and part of the earlier class. To the extent he claimed that his payment was denied because of his incarceration, the court held that he was not entitled to separate individual relief because his request duplicated the class action’s allegations and requested relief. The opinion stated that class members could pursue further action through the class representative and attorney, including contempt proceedings or intervention in the class action.

The court separately rejected Keihl’s request to compel the IRS to provide his payments under the earlier class action or the CARES Act. The earlier ruling prohibited denial based solely on incarceration but did not establish that every incarcerated person was owed a payment. The court also concluded that the December 31, 2020 deadline had passed and that additional funds could no longer be issued under the CARES Act. As a result, Keihl could not obtain the relief requested in this case.

Disposition

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