Whitfield

Background

The case began when the plaintiff, an Arkansas state prisoner proceeding without a lawyer, sent a letter to the Northern District of California. The court filed the letter as a new case to protect his rights.

The plaintiff stated that the Internal Revenue Service sent him an economic impact payment at his prison under the Coronavirus Aid, Relief, and Economic Security Act, commonly called the CARES Act. He claimed that Arkansas had passed a law requiring a prisoner’s payment to be used first for court fines, fees, and restitution. He sought to have the full payment placed in his prison account.

Earlier California Case

The court discussed its earlier decision in Scholl v. Mnuchin, 494 F. Supp. 3d 661 (N.D. Cal. 2020), which held that the Department of the Treasury and the Internal Revenue Service could not withhold certain advance refunds or credits solely because individuals were incarcerated. The court rejected any request to continue the plaintiff’s claim in this court based on that earlier case. It explained that the plaintiff’s claims involved different defendants and alleged interference by an Arkansas state legislature and prison officials, rather than the issuance of funds by the defendants in the earlier case or the CARES Act itself.

Venue and Disposition

Venue is the proper federal district for a case. Applying the federal venue statute, 28 U.S.C. § 1391(b), the court concluded that venue properly lay in the Eastern District of Arkansas because the plaintiff was incarcerated there and his claims concerned defendants in that district. Under 28 U.S.C. § 1406(a), the court transferred the case to the United States District Court for the Eastern District of Arkansas. The order did not decide whether the plaintiff’s underlying payment claims were legally valid.