Reck v. Yellin

Background

Michael R. Reck, a state prisoner proceeding without a lawyer, brought a civil action against a governmental entity. He sought court intervention to obtain economic-impact payments under the Coronavirus Aid, Relief, and Economic Security Act, commonly called the CARES Act. Reck stated that he had not received his payments.

Screening standard

Because Reck was a prisoner seeking relief from a governmental entity, the court was required to screen his complaint under 28 U.S.C. § 1915A. The court had to dismiss claims that were frivolous, malicious, failed to state a claim for relief, or sought money from an immune defendant. The court also applied the rule requiring a complaint to provide enough factual information to give the defendant fair notice and show a plausible entitlement to relief.

Reasoning

The court discussed an earlier class action concerning incarcerated people and CARES Act economic-impact payments. That class action resulted in a declaration that the CARES Act did not allow the defendants to withhold payments solely because a person was or had been incarcerated. The earlier court also found that the policy treating people incarcerated at any time in 2020 as ineligible was arbitrary, capricious, and unlawful, and ordered the defendants to reconsider payments denied solely for that reason.

The court held that Reck was a member of that class. To the extent he argued that his payment had been denied because he was incarcerated, the court said he was not entitled to separate individual injunctive or equitable relief because his request duplicated the class action. The court explained that class members seeking additional equitable or declaratory relief had to pursue it through the class action’s representatives and attorneys, including through contempt proceedings or intervention.

The court also rejected Reck’s request to compel payment under the earlier class action or the CARES Act. The earlier class action did not decide whether any particular incarcerated person was actually owed a payment or the amount owed; those were matters for the Internal Revenue Service to determine individually. In addition, the CARES Act provided that no payment could be made or allowed after December 31, 2020. Because that deadline had passed, the court concluded that Reck could not obtain the relief he requested.

Disposition

The court concluded that Reck 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 without leave to amend, and the clerk was directed to close the case. Judge Phyllis J. Hamilton issued the order on February 22, 2022.