Johnson v. Internal Revenue Service
- Phyllis Hamilton
- 4:21-cv-05269
- U.S. District Court · Northern District of California
- 6
In Willie E. Johnson v. Internal Revenue Service, Judge Hamilton dismissed Johnson’s CARES Act payment case with prejudice because he could not obtain the requested payments.
Willie E. Johnson, a state prisoner representing himself, was affected by the dismissal of his action seeking an economic impact payment from the Internal Revenue Service.
What happened
Willie E. Johnson, a Texas state prisoner representing himself, sued the Internal Revenue Service to obtain an economic impact payment under the CARES Act. He said he had not received the payments and asked the court to require the agency to provide them.
The court said Johnson was already part of a certified class whose members could not be denied payments solely because they were incarcerated, so he could not seek the same relief in a separate case. The court also said the earlier class action did not establish that every incarcerated person was owed a payment, and the CARES Act deadline for issuing payments had passed.
Judge Phyllis J. Hamilton ruled that Johnson failed to state a claim, dismissed the complaint without leave to amend, and dismissed the action with prejudice. The clerk was ordered to close the case.
The detailed version
- Johnson v. Internal Revenue Service · No. 4:21-cv-05269
- Phyllis Hamilton
- Aug. 2, 2021
Background
Willie E. Johnson, a state prisoner in Texas, brought a civil action without a lawyer against the Internal Revenue Service. He had permission to proceed without paying the filing fee. Johnson sought court intervention to obtain an economic impact payment 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 require the Internal Revenue Service to provide them.
Screening standard
Because Johnson was a prisoner suing a governmental entity, the court screened the complaint under 28 U.S.C. § 1915A. That statute requires a court to identify claims that may proceed and dismiss claims that are frivolous, malicious, fail to state a claim for relief, or seek money from an immune defendant. The court also explained that pleadings filed without a lawyer are read liberally, but the complaint still must include enough factual allegations to make the requested relief plausible.
Court’s reasoning
The court explained that an earlier class action had resulted in a declaration that the CARES Act did not allow the government to withhold economic impact payments solely because a person was or had been incarcerated. That class action also required the Internal Revenue Service to reconsider payments denied solely on that basis. Johnson was a member of that class. Because his request for injunctive or equitable relief duplicated the class action’s relief, the court concluded that he was not entitled to separate individual relief on that theory.
The court also rejected Johnson’s request to compel payment under the earlier class action or the CARES Act. The earlier class action had not decided whether any particular incarcerated person was actually owed a payment or how much that person should receive; those were individual determinations for the Internal Revenue Service. In addition, the CARES Act stated that no payment could be made or allowed after December 31, 2020. Because that deadline had passed, the court concluded that Johnson could not obtain the relief he requested.
Disposition
Judge Phyllis J. Hamilton held that Johnson failed to state a claim for relief. The court dismissed the complaint without leave to amend because it found that no amendment could cure the identified deficiencies. The conclusion states that the action was dismissed with prejudice, and the clerk was ordered to close the case.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.