Coy v. Trump
- Phyllis Hamilton
- 4:21-cv-01344
- U.S. District Court · Northern District of California
- 2
In Coy v. Trump, Judge Hamilton denied Coy’s Rule 59(e) motion because he showed no new evidence, clear error, or legal change.
Braidan C. Coy, whose motion to alter or amend the judgment was denied; the order did not grant his request for an economic impact payment.
What happened
Braidan C. Coy, an Indiana state prisoner representing himself, sued a governmental entity and sought help obtaining an economic impact payment under the Coronavirus Aid, Relief, and Economic Security Act. The court denied the case during screening, and Coy asked the court to vacate that decision.
The court treated Coy’s request as a motion to alter or amend the judgment. It explained that such a motion generally requires newly discovered evidence, a clear error, or an intervening change in the law. Coy repeated the arguments from his complaint and did not present any of those grounds. The court also noted that the statutory deadline for issuing the payments had passed and that a claim for damages based on not receiving the payment did not state a claim for relief.
The court denied Coy’s motion. Judge Phyllis J. Hamilton issued the order on November 23, 2021.
The detailed version
- Coy v. Trump · No. 4:21-cv-01344
- Phyllis Hamilton
- Nov. 23, 2021
Background
Braidan C. Coy, an Indiana state prisoner proceeding without a lawyer, filed a civil action against a governmental entity. The court denied the case during screening. Coy then filed a motion to vacate that decision. The court construed the filing as a motion to alter or amend the judgment under Federal Rule of Civil Procedure 59(e).
Coy sought court intervention to obtain an economic impact payment under the Coronavirus Aid, Relief, and Economic Security Act, known as the CARES Act, and relied on an earlier decision from the Northern District of California. The court explained that the earlier decision held that an economic impact payment could not be denied solely because a person was incarcerated, but did not decide whether any particular incarcerated person was owed a payment. The court stated that the Internal Revenue Service was responsible for making that individual determination.
Rule 59(e) Standard
A Rule 59(e) motion must be filed no later than 28 days after judgment. Reconsideration ordinarily requires newly discovered evidence, clear error by the court, or an intervening change in the law. Evidence available before the court’s ruling is not newly discovered for this purpose.
Court’s Analysis
The court found that Coy presented the same arguments he had made in his complaint. It concluded that he had not offered newly discovered evidence, shown clear error, or identified an intervening change in the law. The court also stated that the CARES Act deadline for making or allowing economic impact payments was December 31, 2020, and that the deadline had passed, so no more funds could be issued under that Act.
To the extent Coy sought damages for not receiving the payment, the court stated that the request failed to state a claim for relief. To the extent he sought to bring a separate action related to the earlier case or the CARES Act, the court said he could seek relief in the appropriate district.
Disposition
The court denied Coy’s motion, docketed as No. 17, to alter or amend the judgment. Judge Phyllis J. Hamilton signed the order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.