Cooper v. Doe

Background

Robert J. Cooper, a state prisoner in Maryland proceeding without a lawyer, brought a civil action against a governmental entity. He had permission to proceed without paying the filing fee. Cooper alleged that he had not received economic impact payments (EIPs) under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). He asked the court to require the Internal Revenue Service (IRS) to provide his payments.

Screening standard

Because Cooper was a prisoner suing a governmental entity, the court was required to screen the complaint under 28 U.S.C. § 1915A. Screening is an early review to identify claims that are legally sufficient and dismiss claims that are frivolous, malicious, fail to state a claim, or seek money from an immune defendant. The court also applied the rule requiring a complaint to provide enough factual information to make a plausible claim for relief.

Class-action issue

The court relied on an earlier class action concerning EIPs for people who were or had been incarcerated. In that class action, the court ruled that the CARES Act did not allow the government to withhold an advance refund or credit solely because a person was incarcerated. It also ruled that the policy treating people incarcerated during 2020 as ineligible was unlawful and required the government to reconsider payments denied solely for that reason.

The earlier court expressly did not decide whether any particular class member was actually owed a payment or the amount of any payment. Cooper was a member of that class. Therefore, to the extent his claim was based on denial because of his incarceration, the court said he was not entitled to separate individual injunctive or equitable relief. Individual class members could pursue further action through the class representatives and attorneys, including contempt proceedings or intervention in the class action.

CARES Act deadline and individual eligibility

The court also rejected Cooper’s request to compel payment under the CARES Act or the earlier class action. The earlier ruling required individual eligibility determinations; it did not establish that every incarcerated person was owed an EIP. The court further held that the CARES Act set December 31, 2020, as the deadline for making or allowing the payments. Because that deadline had passed, the court concluded that the requested payments could not be issued and that Cooper could not obtain the relief he sought.

Disposition

The court concluded that Cooper failed to state a claim for relief. It dismissed the complaint without leave to amend because it found that no amendment could cure the identified problems. The conclusion states: “The action is DISMISSED with prejudice.” The clerk was directed to close the case. Judge Phyllis J. Hamilton signed the order.