Smith v. Social Security Administration

Background

Gary Smith, identified as a state prisoner, filed this civil action without a lawyer against a governmental entity. The case had previously been dismissed and closed because Smith had not filed a formal complaint or an application to proceed without paying the filing fee. In this order, the court granted Smith's application and reviewed his complaint under the required screening process for prisoner cases against governmental entities.

Smith sought court intervention to obtain an economic impact payment under the Coronavirus Aid, Relief, and Economic Security Act, commonly called the CARES Act. The opinion states that Smith had not received his payments and asked the court to compel the Internal Revenue Service to provide them.

Screening standard

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 explained that pleadings filed without a lawyer are read liberally, but a complaint still must include enough factual allegations to make the requested relief plausible rather than merely stating conclusions.

Reasons for the ruling

The court relied on an earlier class action concerning economic impact payments for people who were or had been incarcerated. In that case, the court declared that the CARES Act did not allow the government to withhold payments from class members solely because they were incarcerated. It also found that the policy treating people incarcerated during 2020 as ineligible was arbitrary, capricious, and unlawful, and ordered the government to reconsider payments denied solely for that reason.

The earlier court expressly did not decide whether particular class members were actually owed payments or the amount of any payment. Those individual eligibility decisions were left to the Internal Revenue Service.

The court concluded that Smith was part of the earlier class. To the extent he argued that his payment was denied because he was incarcerated, the court said 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 further action through the class representatives and attorneys, including contempt proceedings or intervention in the class action.

The court also rejected Smith's request to compel payment under the earlier class action or the CARES Act. It reasoned that the CARES Act required payments to be made or allowed by December 31, 2020, that the deadline had passed, and that additional funds could not be distributed under the Act. The court therefore found that Smith could not obtain the relief requested in this action.

Disposition

The court held that Smith failed to state a claim for relief. It dismissed the complaint without leave to amend because it determined that no amendment could cure the identified problems. The action remained dismissed and closed. Judge Phyllis J. Hamilton ordered that the decision take effect.