Randle v. Internal Revenue Service

Background

Willie Randle, a state prisoner in Texas proceeding without a lawyer, filed a civil action against the Internal Revenue Service and other defendants. He paid the filing fee and submitted an original complaint followed by an amended complaint. Randle 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.

Screening standard

Because Randle is a prisoner seeking relief from a governmental entity, the court was required to conduct an initial screening under 28 U.S.C. § 1915A. At that stage, the court must 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 requirement that a complaint provide enough factual allegations to make a claim plausible, while construing a self-represented litigant’s filings liberally.

Earlier class action

The court discussed an earlier related class action concerning economic impact payments for incarcerated people. The CARES Act created a tax credit for eligible individuals and authorized advance payments of that credit. The Internal Revenue Service had adopted a policy stating that incarcerated people did not qualify for the payments.

In that earlier class action, the court certified a class that included certain incarcerated United States citizens and lawful permanent residents who met specified tax-filing, dependency, and Social Security number requirements. It declared that the CARES Act did not authorize withholding payments solely because a person was or had been incarcerated, and it found the Internal Revenue Service’s incarceration-based policy arbitrary, capricious, and contrary to law. The court also required the agency to reconsider payments denied solely for that reason.

The earlier court expressly did not decide whether particular plaintiffs or class members were actually owed payments or how much they were owed. It left those individual eligibility decisions to the Internal Revenue Service.

Application to Randle

The court found that Randle was incarcerated and part of the earlier class. To the extent he claimed that the Internal Revenue Service denied his payment solely because of his incarceration, the court held that he was not entitled to separate individual injunctive or equitable relief because that claim duplicated the existing class action. The court stated that class members must pursue additional action through the class representatives and attorneys, including contempt proceedings or intervention in the class action.

The court separately rejected Randle’s request to compel payment under the earlier ruling or the CARES Act. The earlier ruling prevented denial based solely on incarceration but did not establish that Randle was individually owed a payment. In addition, the CARES Act required payments to be made or allowed by December 31, 2020. Because that deadline had passed, the court concluded that the requested payments could no longer be issued under the Act.

Disposition

The court concluded that Randle failed to state a claim for relief. It stated that no amendment could cure the identified problems. Randle’s motion for leave to file an amended complaint was granted, and the court reviewed the amended filing. The action was then dismissed with prejudice, and the clerk was directed to close the case. The order was signed by Judge Phyllis J. Hamilton on September 7, 2021.