Cochran v. Internal Revenue Service

Background

Antonio Lamar Cochran, a Texas state prisoner proceeding without a lawyer, brought a civil action against the Internal Revenue Service. The court had allowed him to proceed without prepaying filing fees. Cochran 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.

The CARES Act created an advance tax refund for eligible individuals and set December 31, 2020, as the deadline after which an advance refund or credit could not be made or allowed under the relevant provision. The opinion also discussed an earlier related class action involving incarcerated people and the IRS’s policy of treating incarceration as a reason to deny economic-impact payments.

Screening and Earlier Class Action

Because Cochran was a prisoner suing a governmental entity, the court was required to screen the complaint under 28 U.S.C. § 1915A. That screening requires dismissal of claims that are frivolous, malicious, fail to state a claim for relief, or seek money from a defendant protected from such relief. The court also applied the rule requiring a complaint to provide enough factual matter to make a claim plausible, rather than relying only on labels or conclusions.

The court stated that Cochran was a member of the class certified in the earlier related proceeding. In that proceeding, the court declared that the CARES Act did not allow the defendants to withhold payments solely because a person was or had been incarcerated. It also found that the IRS policy treating people incarcerated at any time in 2020 as ineligible was arbitrary, capricious, and unlawful, 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 owed payments or the amount of any payment. Individual eligibility determinations remained the IRS’s responsibility.

Court’s Analysis

The court held that Cochran could not obtain separate individual injunctive or equitable relief based on the same allegations and requested relief covered by the earlier class action. As a class member, he was not entitled to pursue duplicative individual relief in this separate action.

The court separately rejected Cochran’s request to compel payment under the earlier class-action decision or the CARES Act. The earlier decision barred denial based solely on incarceration but did not establish that every incarcerated person was owed a payment. In addition, the December 31, 2020 statutory deadline had passed, so the court concluded that the requested payments could no longer be distributed under the CARES Act.

Disposition

The court concluded that Cochran failed to state a claim for relief. It dismissed the complaint without leave to amend because no amendment could cure the identified deficiencies. In the conclusion, the court stated: “The action is DISMISSED with prejudice.” The clerk was ordered to close the case. Judge Phyllis J. Hamilton signed the order.