Harris v. Cisneros

Background

Marvin Harris, a state prisoner proceeding without a lawyer, brought a civil action against a governmental entity and was allowed to proceed without paying the filing fee. His complaint was not entirely clear, but the court understood it to seek an order requiring the Internal Revenue Service to provide an economic impact payment under the Coronavirus Aid, Relief, and Economic Security Act, commonly called the CARES Act.

The court described the CARES Act’s economic impact payment as an advance payment of a tax credit for eligible individuals. The law stated that no refund or credit could be made or allowed under the relevant provision after December 31, 2020.

The court also discussed an earlier class action, Scholl, concerning incarcerated people whose payments were denied solely because of their incarceration. That court declared that the CARES Act did not allow the government to withhold payments from class members solely for that reason and ordered the government to reconsider such payments. But the earlier court did not decide whether any particular person was actually owed a payment or the amount of any payment.

Court’s Analysis

Because Harris was incarcerated and was part of the Scholl class, the court said he was not entitled to separate individual injunctive or equitable relief to the extent his payment was denied because of his incarceration. Individual relief that duplicates an existing class action may be dismissed; class members must pursue further action through the class representatives and attorneys, including through contempt proceedings or intervention in the class action.

The court also rejected any request to compel payment under Scholl or the CARES Act. Scholl barred denial based solely on incarceration but left individual eligibility determinations to the Internal Revenue Service. More importantly, the statutory deadline for issuing or allowing the payments had passed, so the court concluded that Harris could not obtain the relief requested.

The court further stated that, to the extent Harris alleged that prison officials at his facility in the Eastern District of California interfered with or seized his payment, he would have to bring that action in the Eastern District of California.

Disposition

The court concluded that Harris failed to state a claim for relief. Judge Phyllis J. Hamilton dismissed the action without leave to amend because no amendment could cure the identified deficiencies. The clerk was directed to close the case. The order did not decide the alleged prison-official interference claim in the Eastern District of California; it stated that such a claim must be filed there.