Clay v. Department of Treasury

Background

Thomas Clay, identified in the opinion as a Texas state prisoner, brought a civil action without a lawyer against the Department of Treasury and other defendants. He had been allowed to proceed without paying the filing fee. Clay sought court intervention to obtain economic impact payments under the Coronavirus Aid, Relief, and Economic Security Act, commonly called the CARES Act. He stated that he had not received his payments and requested an order compelling the Internal Revenue Service to provide them, along with money damages.

Screening standard

Because Clay was a prisoner suing a governmental entity, the court conducted preliminary screening under 28 U.S.C. § 1915A. That statute requires the court to identify claims that can proceed and dismiss claims that are frivolous, malicious, inadequately pleaded, or seek money from an immune defendant. The court also explained that complaints filed without a lawyer are read liberally, but they still must contain enough factual allegations to make the requested relief plausible.

The related class action

The opinion discussed an earlier related proceeding that certified a class including certain United States citizens and lawful permanent residents who were or had been incarcerated and otherwise met the CARES Act’s eligibility requirements. In that proceeding, the court declared that the Act did not authorize withholding advance refunds or credits from class members solely because they were incarcerated. It also declared that the policy treating people incarcerated at any time in 2020 as ineligible was arbitrary, capricious, and unlawful, and entered a permanent injunction requiring reconsideration of payments denied solely for that reason.

The earlier court expressly took no position on whether particular plaintiffs or class members were actually owed payments or on the amount of any payment. It left the Internal Revenue Service responsible for making individual eligibility determinations.

Court’s reasoning

The court found that Clay was a member of the earlier class. To the extent he claimed that his payment was denied because he was incarcerated, the court held that he was not entitled to separate individual equitable relief because his claim duplicated the existing class action. The opinion stated that class members must pursue additional actions through the class representative and attorney, including contempt proceedings or intervention in the class action.

The court separately rejected Clay’s request to compel payment under the earlier proceeding or the CARES Act. The earlier proceeding did not establish that every incarcerated person was owed a payment; it only barred denial based solely on incarceration. In addition, the CARES Act provided that no advance refund or credit could be made or allowed after December 31, 2020. Because that deadline had passed, the court concluded that the requested payments could not be distributed under the Act.

Disposition

The court held that Clay failed to state a claim for relief. It dismissed the complaint without leave to amend because it found that no amendment could cure the identified deficiencies. The action was dismissed with prejudice. The court also denied Clay’s motion for a telephonic hearing and directed the clerk to close the case.