Wheeler v. Inch

Background

Jimmy Lee Wheeler, identified as an incarcerated Florida state prisoner, brought a civil action against Mark S. Inch and other defendants. He represented himself and had permission to proceed without paying the filing fee. Wheeler 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 the payments and asked the court to compel the Internal Revenue Service to provide them.

Screening standard

Because Wheeler was a prisoner suing a governmental entity, the court was required to screen the complaint 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 protected from that type of relief. The court also stated that complaints filed by people without lawyers must be read liberally, but they still must include enough factual allegations to make the requested relief plausible rather than speculative.

Reasons for dismissal

The court relied on an earlier class action concerning economic impact payments and incarcerated people. That case held that the CARES Act did not allow the defendants to withhold payments solely because a person was or had been incarcerated, and it required reconsideration of payments denied for that reason. The earlier case did not decide whether any particular person was actually owed a payment or how much that payment should be. Those individual determinations were left to the Internal Revenue Service.

The court found that Wheeler was a member of that class. To the extent he claimed that his payment had been denied solely because he was incarcerated, the court said he was not entitled to separate individual injunctive or equitable relief duplicating the existing class action. To the extent he sought an order requiring payment under the earlier case or the CARES Act, the court found that the CARES Act’s December 31, 2020 deadline for payments had passed and that no additional payments could be issued under that Act. The court therefore concluded that Wheeler could not obtain the relief he requested.

Disposition

The court held that Wheeler failed to state a claim for relief. It dismissed the action without leave to amend because it found that no amendment could cure the identified problems. The clerk was directed to close the case. The court further stated that any claim concerning Wheeler’s Florida prison improperly using the payments for restitution had to be brought in the appropriate Florida court. Judge Phyllis J. Hamilton signed the order on January 11, 2022.