Ridge v. Treasury Internal Revenue Service Austin
- Phyllis Hamilton
- 4:21-cv-07400
- U.S. District Court · Northern District of California
- 6
In Deshaun Ridge v. Treasury Internal Revenue Service Austin, Judge Hamilton dismissed Ridge’s request for economic-impact payments with prejudice.
Deshaun Ridge, an incarcerated plaintiff proceeding without a lawyer, was affected by the dismissal of his request for economic-impact payments. The order also addressed his membership in an existing class action involving incarcerated people and those payments.
What happened
Deshaun Ridge v. Treasury Internal Revenue Service Austin involved a Texas state prisoner representing himself and seeking economic-impact payments under the Coronavirus Aid, Relief, and Economic Security Act. Ridge said he had not received the payments and asked the court to require the Internal Revenue Service to provide them.
The court said Ridge was already part of a class action covering incarcerated people whose payments were denied solely because of incarceration, so he could not obtain separate individual relief on that basis. The court also explained that the class action did not decide whether any particular person was owed a payment, and that the law’s December 31, 2020 deadline for issuing the payments had passed. The court therefore found that Ridge could not obtain the relief he requested.
Judge Phyllis J. Hamilton ruled that Ridge failed to state a claim for relief. She dismissed the action with prejudice and without leave to amend, and directed the clerk to close the case.
The detailed version
- Ridge v. Treasury Internal Revenue Service Austin · No. 4:21-cv-07400
- Phyllis Hamilton
- Oct. 12, 2021
Background
Deshaun Ridge, a state prisoner in Texas proceeding without a lawyer, brought a civil action against Treasury Internal Revenue Service Austin. He was allowed to proceed without paying the filing fee. The opinion states that he filed the case on September 22, 2021, and alleged that he had not received his 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 to provide the payments.
Screening standard
Because Ridge was a prisoner suing a governmental entity, the court conducted the required preliminary screening under 28 U.S.C. § 1915A. The court had to identify claims that could proceed and dismiss claims that were frivolous, malicious, failed to state a claim for relief, or sought money from a defendant immune from that relief. The court also noted that it must read pleadings filed without a lawyer liberally, but that a complaint still must include enough factual allegations to make a claim plausible rather than merely assert labels or conclusions.
Analysis
The court relied on earlier litigation concerning EIPs for incarcerated people. That litigation resulted in a certified class including qualifying United States citizens and lawful permanent residents who were or had been incarcerated and who met specified tax-filing, dependency, and Social Security number requirements. The earlier court declared that 26 U.S.C. § 6428 did not allow the government to withhold advance refunds or credits from class members solely because they were or had been incarcerated. It also found the policy treating people incarcerated at any time in 2020 as ineligible to be arbitrary, capricious, and contrary to law, and entered a permanent injunction requiring reconsideration of payments denied solely for that reason.
The opinion states that Ridge was incarcerated and was part of that class. To the extent he claimed that his payment was denied because of his incarceration, the court held that he was not entitled to separate individual relief because his claim duplicated the existing class action. The court explained that class members could pursue further action through the class representatives and attorneys, including contempt proceedings or intervention in the class action.
The court separately rejected Ridge’s request to require payment under the earlier litigation or the CARES Act. The earlier litigation did not decide whether any particular incarcerated person was owed an EIP or the amount of any payment; those determinations were left to the Internal Revenue Service. In addition, the CARES Act barred issuing or allowing refunds or credits after December 31, 2020. Because that deadline had passed, the court concluded that Ridge could not obtain the relief requested.
Disposition
The court concluded that Ridge failed to state a claim for relief. Judge Phyllis J. Hamilton dismissed the complaint without leave to amend because she found that no amendment could cure the identified problems. The action was dismissed with prejudice, and the clerk was directed to close the case.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.