Carpenter v. Internal Revenue Service

Background

David Wayne Carpenter, a Georgia state prisoner proceeding without a lawyer, brought a civil action against the Internal Revenue Service. The court had allowed him to proceed without paying the filing fee. Carpenter sought court intervention to obtain an economic impact payment under the Coronavirus Aid, Relief, and Economic Security Act, commonly called the CARES Act.

Screening standard

Because Carpenter was a prisoner suing a governmental entity, the court screened the complaint under 28 U.S.C. § 1915A. That law requires dismissal of claims that are frivolous, malicious, fail to state a claim for relief, or seek money from an immune defendant. The court also applied the requirement that a complaint contain enough factual allegations to make the requested relief plausible, while construing a self-represented litigant’s allegations liberally.

Existing class action

The court discussed an earlier class action concerning economic impact payments for people who were or had been incarcerated. In that case, the court declared that the CARES Act did not authorize the government to withhold payments solely because a person was incarcerated, and it found that the IRS policy treating incarcerated people as ineligible on that basis was unlawful. The court also required the IRS to reconsider payments denied solely for that reason.

The earlier class action did not decide whether any particular person was entitled to a payment or the amount of any payment. Those individual determinations were left to the IRS.

Reasons for dismissal

The court found that Carpenter was a member of the existing class. To the extent he claimed that his payment was denied because he was incarcerated, he was not entitled to separate individual injunctive or equitable relief duplicating the class action. The court stated that class members must pursue additional action through the class representatives and attorneys, including through contempt proceedings or intervention in the class action.

The court separately rejected Carpenter’s request to compel payment under the CARES Act or the earlier class-action decision. 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 the requested relief could no longer be provided.

The court also referred to allegations that prison officials at Carpenter’s facility in Georgia interfered with his mail and his payment. It stated that those claims must be brought in the appropriate federal district in Georgia.

Disposition

The court concluded that Carpenter failed to state a claim for relief. It dismissed the action without leave to amend because it found that no amendment could cure the deficiencies. The clerk was ordered to close the case. Judge Phyllis J. Hamilton signed the order on February 7, 2023.