Buchta v. Department of the Treasury

Background

Eugene Buchta, a Maryland state prisoner proceeding without a lawyer, brought a civil action against the Department of the Treasury and other defendants. He sought an order requiring the Internal Revenue Service to provide economic impact payments under the Coronavirus Aid, Relief, and Economic Security Act.

The court explained that the Act created tax credits and advance payments for eligible individuals. The Act also stated that no payment or credit could be made or allowed under the relevant provision after December 31, 2020.

Related class action

The court discussed an earlier class action concerning incarcerated people and economic impact payments. In that case, the court declared that the Act did not allow the defendants to withhold payments solely because a person was or had been incarcerated. It also found that the policy treating people who had been incarcerated during 2020 as ineligible was arbitrary, capricious, and unlawful, and entered an injunction requiring the defendants to reconsider payments denied solely for that reason.

The earlier court did not decide whether particular people were actually owed payments or how much they were owed. Those individual eligibility decisions were left to the Internal Revenue Service.

Court’s analysis

The court found that Buchta was incarcerated and was part of the earlier class. To the extent he claimed that his payments were denied because of his incarceration, the court said he was not entitled to separate individual injunctive or equitable relief duplicating the existing class action. The court stated that class members seeking additional action had to pursue it through the class representatives and attorneys or seek intervention in the class action.

The court also rejected Buchta’s request for an order compelling payment under the earlier class action or the Act. The earlier ruling established only that incarceration alone could not justify denying a payment; it did not establish that each incarcerated person was owed a payment. In addition, the December 31, 2020 statutory deadline had passed, so the court concluded that no further payments could be distributed under the Act.

Disposition

During prisoner screening, the court concluded that Buchta failed to state a claim for relief. It dismissed the complaint without leave to amend because no amendment could cure the identified problems. The court then dismissed the action with prejudice and directed the clerk to close the case.