Vaughan v. U.S. Department of Treasury

Background

Donald Doc Vaughan, a state prisoner in Maryland, filed a civil action against a governmental entity without a lawyer. He had previously been allowed to proceed without paying the filing fee. Vaughan sought court intervention to obtain 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 and asked the court to require the Internal Revenue Service to provide them.

Screening standard

Because Vaughan was a prisoner suing a governmental entity, the court screened the complaint under 28 U.S.C. § 1915A. That law requires the court to identify claims that can proceed and dismiss claims that are frivolous, malicious, inadequately pleaded, or seek money from an immune defendant. The court also applied the rule requiring a complaint to provide enough factual content to make a claim plausible, while construing a self-represented litigant’s allegations liberally.

Prior class action

The court discussed an earlier class action concerning economic impact payments for incarcerated people. That class action established that the CARES Act did not allow the defendants to withhold payments from class members solely because they were or had been incarcerated. It also held that the policy treating people incarcerated at any time in 2020 as ineligible was arbitrary, capricious, and unlawful, and required the Internal Revenue Service to reconsider payments denied solely for that reason.

The earlier court did not decide whether any particular class member was actually owed a payment or how much that person should receive. Instead, the Internal Revenue Service remained responsible for making individual eligibility determinations. Vaughan was part of that class.

Ruling

The court held that Vaughan could not obtain separate injunctive or equitable relief based on the same incarceration-related allegations and requested relief because he was already covered by the class action. The court also rejected his request to compel payment under the earlier class action or the CARES Act. It explained that the earlier case did not establish his individual entitlement to a payment and that the CARES Act deadline of December 31, 2020, for payments to be made or allowed had passed. The court therefore concluded that Vaughan could not obtain the relief he requested.

The court ruled that Vaughan failed to state a claim for relief. It dismissed the complaint without leave to amend because no amendment could cure the identified problems. In the conclusion, the court ordered that the action be dismissed with prejudice and directed the clerk to close the case. Judge Phyllis J. Hamilton signed the order.