Jenkins

Background

Jenkins, a state prisoner representing himself, is incarcerated in the Eastern District of Michigan. He brought civil-rights claims against defendants in that district. According to the opinion, the Internal Revenue Service sent Jenkins an economic impact payment under the Coronavirus Aid, Relief, and Economic Security Act. Jenkins alleged that prison officials deducted money from the payment for restitution and other charges. He sought an order requiring Michigan prison officials to provide him with the funds.

Earlier case

The court noted that, in an earlier case, it had ruled that the Department of the Treasury and the Internal Revenue Service could not withhold advance refunds or credits solely because a person was incarcerated. The court denied, to the extent Jenkins requested it, proceeding with his claim in this court or in that earlier case. It explained that Jenkins's claims involved different defendants and alleged interference by prison officials with his receipt of the payment, rather than the issuance of funds by the defendants in the earlier case or under the CARES Act.

Ruling

The court ruled that venue—the proper federal district for the case—lay in the Eastern District of Michigan rather than the Northern District of California. Judge Phyllis J. Hamilton therefore transferred the case to the United States District Court for the Eastern District of Michigan under 28 U.S.C. § 1406(a). The opinion does not decide whether Jenkins's underlying claim about the deducted funds is valid.