Wood

Background

Russell Raymond Wood, a state prisoner, brought a pro se civil action against a governmental entity. He sought an order requiring the Internal Revenue Service to provide economic impact payments under the Coronavirus Aid, Relief, and Economic Security Act, commonly called the CARES Act. The court had allowed him to proceed without paying the filing fee.

Screening standard

Because Wood was a prisoner seeking relief from 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, or seek money from an immune defendant. The court also applied the rule requiring a complaint to contain enough factual matter to make a claim plausible, while construing a self-represented litigant’s allegations liberally.

Earlier class action

The court discussed an earlier related 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 permit the defendants to withhold payments solely because a person was incarcerated and found that the policy treating people incarcerated during 2020 as ineligible was unlawful. The earlier court ordered the Internal Revenue Service to reconsider payments denied solely for that reason.

The earlier court expressly did not decide whether any particular class member was actually owed a payment or the amount of any payment. Those individual eligibility decisions were left to the Internal Revenue Service.

Application to Wood’s claim

The court found that Wood was incarcerated and part of the earlier class. To the extent he claimed that his payment had been denied because of his incarceration, the court said he was not entitled to separate individual injunctive or equitable relief duplicating the class action. The court stated that class members seeking additional equitable or declaratory relief must pursue it through the class action’s procedures.

The court also rejected Wood’s request for an order requiring payment under the earlier case or the CARES Act. The earlier decision established only that incarceration alone could not be the reason for denying a payment; it did not establish that every incarcerated person was individually owed a payment. In addition, the CARES Act provided that payments could not be issued or allowed after December 31, 2020. Because that deadline had passed, the court concluded that Wood could not obtain the requested relief.

Disposition

The court held that Wood 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 problems. The action was dismissed, and the clerk was ordered to close the case. Judge Hamilton signed the order on May 4, 2023.