Aruanno v. I.R.S.
- Phyllis Hamilton
- 4:22-cv-08915
- U.S. District Court · Northern District of California
- 2
In Aruanno v. I.R.S., Judge Hamilton transferred the case to New Jersey because the alleged conduct and defendants were there.
Joseph Aruanno’s case was transferred from the Northern District of California to the District of New Jersey; the court did not decide the underlying payment claim.
What happened
In Aruanno v. I.R.S., Joseph Aruanno, a New Jersey state prisoner representing himself, said prison officials were withholding economic impact payments sent to him under the CARES Act. He sought money damages and payment of the funds.
The court said the case concerned conduct by prison officials in New Jersey, not the Internal Revenue Service’s issuance of the payments addressed in an earlier California case. It therefore found that the proper location for the case was the District of New Jersey.
Judge Phyllis J. Hamilton transferred the case to the United States District Court for the District of New Jersey. The court also denied the pending motion as moot.
The detailed version
- Aruanno v. I.R.S. · No. 4:22-cv-08915
- Phyllis Hamilton
- Feb. 9, 2023
Background
Joseph Aruanno, a New Jersey state prisoner proceeding without a lawyer, brought a civil action against the Internal Revenue Service. He alleged that the Internal Revenue Service sent him an economic impact payment under the Coronavirus Aid, Relief, and Economic Security Act, but that prison officials in New Jersey were withholding the payment from him and other prisoners. He sought money damages and an order requiring that the payments be provided.
Venue analysis
The court distinguished this case from an earlier case in which the Northern District of California held that the Department of the Treasury and the Internal Revenue Service could not withhold advance refunds or credits solely because individuals were incarcerated. The court explained that Aruanno’s claim involved different defendants and different conduct: alleged interference by prison officials who were withholding the payments, rather than the issuance of the payments by the parties involved in that earlier case.
Under 28 U.S.C. § 1391(b), the court concluded that venue—the proper federal court location for the case—was in the District of New Jersey because Aruanno was incarcerated there and his claim concerned defendants and conduct in that district.
Disposition
The court transferred the case to the United States District Court for the District of New Jersey under 28 U.S.C. § 1406(a). It denied the pending motion, identified as Docket No. 2, as moot. The order did not decide whether Aruanno was entitled to the payments or damages.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.