Escamilla v. Department of Treasury

Background

Austin G. Escamilla, a state prisoner in Texas, filed a civil action without a lawyer against the Department of Treasury. The court had allowed him to proceed without paying the filing fee. Escamilla 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 and asked the court to compel the Internal Revenue Service to provide them.

Screening standard

Because Escamilla was a prisoner suing a governmental entity, the court screened the complaint under 28 U.S.C. § 1915A. This screening requires dismissal of claims that are frivolous, malicious, fail to state a legally sufficient claim, or seek money from a defendant immune from that relief. The court also applied the requirement that a complaint provide enough factual allegations to make the requested relief plausible, while construing a self-represented litigant’s pleadings liberally.

Existing class action

The court discussed an earlier related class action involving economic-impact payments for incarcerated people. That class action declared that the CARES Act did not allow the government to withhold payments solely because a person was or had been incarcerated. It also found that the government’s policy treating people incarcerated at any time in 2020 as ineligible was arbitrary, capricious, and unlawful, and ordered the government to reconsider payments denied solely for that reason.

The earlier case did not decide whether any particular incarcerated person was actually owed a payment or how much that person should receive. Those individual eligibility decisions were left to the Internal Revenue Service.

Ruling

The court found that Escamilla was a member of the earlier class. To the extent he claimed that his payment had been denied because he was incarcerated, the court held that he was not entitled to separate individual injunctive or equitable relief duplicating the existing class action. The court stated that class members could pursue further action through the class representatives and attorneys, including contempt proceedings or intervention in the class action.

To the extent Escamilla sought an order requiring payment under the earlier class action or the CARES Act, the court held that he could not obtain that relief. The CARES Act required payments to be made or allowed by December 31, 2020, and the court stated that the deadline had passed and no additional funds could be issued under the Act.

Judge Phyllis J. Hamilton concluded that Escamilla failed to state a claim for relief. The court dismissed the complaint without leave to amend because it found that no amendment could correct the stated deficiencies. In the conclusion, the court ordered that the action be dismissed with prejudice and directed the clerk to close the case.