Miller v. Dean
- Phyllis Hamilton
- 4:23-cv-01783
- U.S. District Court · Northern District of California
- 5
In Miller v. Dean, Judge Hamilton dismissed Miller’s request for replacement economic relief payments because the payment deadline had passed.
Elijah Lee Miller, a state prisoner seeking replacement economic impact payments, and the governmental defendants named in the action.
What happened
In Miller v. Dean, Elijah Lee Miller, a state prisoner representing himself, sued government defendants over economic relief payments created by the Coronavirus Aid, Relief, and Economic Security Act. He said payments had been sent but he never received them because they were lost or mailed to the wrong person.
The court explained that an earlier class case prevented the government from denying payments solely because someone was incarcerated, but it did not decide whether any particular person was owed money. The court also said the payment deadline had passed, so it could not order new payments under that law.
Judge Phyllis J. Hamilton dismissed the action for failure to state a claim and closed the case. The court said Miller could seek to reopen the case if he learned relevant additional information.
The detailed version
- Miller v. Dean · No. 4:23-cv-01783
- Phyllis Hamilton
- May 15, 2023
Background
Elijah Lee Miller, a state prisoner proceeding without a lawyer, brought a civil action against a governmental entity. He had permission to proceed without paying the filing fee. His claim concerned economic impact payments created by the Coronavirus Aid, Relief, and Economic Security Act, commonly called the CARES Act.
Miller alleged that economic impact payments had been sent to him but that he did not receive them because they were lost or mailed to the wrong person. He asked the court to require the Internal Revenue Service to issue replacement payments.
Screening standard
Because Miller was a prisoner suing a governmental entity, the court was required to screen the complaint under 28 U.S.C. § 1915A. The court had to identify claims that could proceed and dismiss claims that were frivolous, malicious, failed to state a claim for relief, or sought money from an immune defendant. The court also noted that complaints filed without a lawyer are read generously, but they still must include enough facts to make a requested legal remedy plausible.
Earlier class case
The court discussed an earlier class action concerning economic impact payments for incarcerated people. That case held that 26 U.S.C. § 6428 did not allow the government to withhold payments solely because a person was or had been incarcerated. It also held that the government’s policy treating people incarcerated at any time in 2020 as ineligible was unlawful and required the government to reconsider payments denied solely for that reason.
But the earlier court expressly took no position on whether a particular class member was actually owed a payment or on the amount of any payment. Individual eligibility determinations remained the responsibility of the Internal Revenue Service.
Court’s reasoning
The court held that Miller could not obtain an order requiring the Internal Revenue Service to reissue his payments under the earlier class case or the CARES Act. The earlier case addressed denial based solely on incarceration; it did not establish that every incarcerated person was owed a payment.
The court also relied on the CARES Act’s December 31, 2020 deadline for making or allowing the payments. Because that deadline had passed, the court stated that no additional funds could be issued under the Act. The court further stated that merely not receiving a payment did not give it jurisdiction over the matter.
Disposition
The action was DISMISSED for failure to state a claim. The clerk was ordered to close the case. The court stated that Miller could seek to reopen the case if he learned more relevant information. The opinion does not state that the dismissal was with or without prejudice.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.