Thomas v. Internal Revenue Service

Background

Ronald Thomas, a Texas state prisoner proceeding without a lawyer, filed a civil action against the Internal Revenue Service. The court denied the case during screening. Thomas then filed a motion under Federal Rule of Civil Procedure 59(e) asking the court to alter or amend the judgment.

Thomas sought court intervention to obtain an economic impact payment under the Coronavirus Aid, Relief, and Economic Security Act. The court had previously advised that he was not entitled to relief requiring the Internal Revenue Service to provide the payment. The court explained that an earlier decision had held that an economic impact payment could not be denied solely because a person was incarcerated, but had not decided whether any particular incarcerated person was owed a payment. That determination was left to the Internal Revenue Service. The court also stated that the Act’s December 31, 2020 deadline for making or allowing the payments had passed, so no additional funds could be issued under the Act.

Rule 59(e) standard

A Rule 59(e) motion must be filed within 28 days after judgment. Reconsideration under that rule generally requires newly discovered evidence, a clear error by the court, or an intervening change in the law. Evidence that was available before the court’s ruling is not newly discovered for this purpose.

Court’s ruling

Thomas repeated the arguments from his complaint and did not present newly discovered evidence, show clear error, or identify an intervening change in the law. Regarding his Equal Protection claim, the court found that he had not shown that he was treated differently from similarly situated people in an improper way. The fact that some inmates received economic impact payments while Thomas did not, without more, was insufficient to establish an Equal Protection violation.

Judge Hamilton denied Thomas’s motion to alter or amend the judgment. The opinion does not state that the motion was denied with or without prejudice.