Thomas v. Internal Revenue Service

Background

Ronald Thomas, a state prisoner in Texas proceeding without a lawyer, brought a civil action against the Internal Revenue Service. He had been allowed to proceed without paying the filing fee. Thomas sought an order requiring the IRS to provide 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 Thomas was a prisoner suing a governmental entity, the court was required to screen the complaint under 28 U.S.C. § 1915A. The court had to identify claims that could proceed and dismiss claims that were frivolous, malicious, failed to state a claim for relief, or sought money from an immune defendant. The court also applied the rule that a complaint must provide enough factual allegations to make a claimed entitlement to relief plausible, rather than relying only on labels or legal conclusions.

Prior class action

The court discussed an earlier related class action concerning economic impact payments for incarcerated people. That court had declared that 26 U.S.C. § 6428 did not allow the defendants to withhold payments from class members solely because they were or had been incarcerated. It also declared that the IRS policy treating people incarcerated at any time in 2020 as ineligible was arbitrary, capricious, and contrary to law, and entered a permanent injunction requiring reconsideration of payments denied solely for that reason.

The earlier court expressly did not decide whether particular plaintiffs or class members were actually owed payments or the amount of any payment. Individual eligibility determinations remained the IRS’s responsibility.

Court’s reasoning

The court found that Thomas was incarcerated and part of the earlier class. To the extent he claimed that the IRS denied his payment solely because of his incarceration, the court held that he was not entitled to separate individual injunctive or equitable relief because that request duplicated the existing class action. The court stated that class members could pursue such relief through the class representatives and attorneys, including through further proceedings in the class action or intervention.

The court also rejected Thomas’s request for an order requiring payment under the earlier class action or the CARES Act. The earlier class action established only that incarceration alone could not justify denial; it did not establish that every incarcerated person was owed a payment. In addition, the CARES Act set December 31, 2020, as the deadline after which an economic impact payment could no longer be made or allowed. Because that deadline had passed, the court concluded that Thomas could not obtain the requested relief.

Disposition

The court concluded that Thomas 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 court then ordered that the action be dismissed with prejudice and that the clerk close the case. Judge Phyllis J. Hamilton signed the order.