Martinez v. Internal Revenue Service

Background

Leonel Miranda Martinez, a Kentucky state prisoner proceeding pro se, sued the Internal Revenue Service. He had been allowed to proceed without paying the filing fee. Martinez 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.

Screening standard

Because Martinez was a prisoner suing a governmental entity, the court screened his complaint under 28 U.S.C. § 1915A. That screening process requires dismissal of claims that are frivolous, malicious, inadequately pleaded, or seek money from a defendant protected from such relief. The court also applied the rule requiring a complaint to provide enough factual information to make the requested relief plausible.

The earlier class action

The court discussed an earlier related class action concerning incarcerated people and economic impact payments. In that case, the court declared that 26 U.S.C. § 6428 did not allow the government to withhold advance payments or credits from class members solely because they were or had been incarcerated. It also declared that the IRS 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 did not decide whether any particular person was actually owed a payment or how much that person should receive. It left those individual eligibility determinations to the IRS.

Reasons for dismissal

The court found that Martinez was incarcerated and part of the earlier class. To the extent he claimed that his payments were denied because of his incarceration, the court held that he was not entitled to separate individual injunctive or equitable relief because his claim duplicated the existing class action. The court stated that class members seeking additional action must pursue it through the class representatives and attorneys, including through contempt proceedings or intervention in the class action.

The court separately rejected Martinez’s request to compel the IRS to provide his payments under the earlier class action or the CARES Act. The earlier ruling only prohibited denial based solely on incarceration; it did not establish that every incarcerated person was owed a payment. In addition, the CARES Act required payments or credits to be made or allowed by December 31, 2020. The court held that this deadline had passed and that no more funds could be issued under the Act. Martinez therefore could not obtain the relief he requested in this case.

Disposition

The court concluded that Martinez 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 problems. The action was dismissed with prejudice, and the clerk was ordered to close the case.

Judge

The order was signed by United States District Judge Phyllis J. Hamilton.