McCoy v. IRS

Background

Hickory McCoy and another plaintiff, described in the opinion as a California federal prisoner and a Florida federal prisoner, brought a civil action against the Internal Revenue Service without lawyers. They had permission to proceed without paying the filing fee. The plaintiffs sought court intervention to obtain economic impact payments under the Coronavirus Aid, Relief, and Economic Security Act, and sought to hold the defendants in contempt for allegedly failing to provide those payments.

The opinion discussed an earlier related class action concerning incarcerated people and the same payments. In that earlier proceeding, the court declared that the statute did not allow the government to withhold advance refunds or credits solely because a person was or had been incarcerated. The earlier court also required the Internal Revenue Service to reconsider payments denied solely for that reason. But that court expressly did not decide whether any individual class member was entitled to a payment or the amount of any payment. The opinion states that McCoy and the other plaintiff were members of that class.

Screening standard

Because the plaintiffs were prisoners suing a governmental entity, the court screened the complaint under 28 U.S.C. § 1915A. The screening statute requires dismissal of claims that are frivolous, malicious, fail to state a claim for relief, or seek money from a defendant immune from that relief. The court also applied the requirement that a complaint provide enough factual material to make a claim plausible, while construing filings by people without lawyers liberally.

Court’s analysis

The court rejected the request for contempt relief because the earlier related case was closed and the plaintiffs had not shown that the defendants should be held in contempt.

The court also rejected the request to compel payment under the earlier case or the CARES Act. The earlier ruling prohibited denying a payment solely because of incarceration, but left individual eligibility determinations to the Internal Revenue Service. More importantly, the court stated that the CARES Act’s December 31, 2020 deadline for making or allowing the payments had passed and that no additional funds could be issued. The plaintiffs therefore could not obtain the relief requested in this case.

Disposition

The court concluded that the plaintiffs failed to state a claim for relief. It dismissed the action without leave to amend because it found that no amendment could cure the identified deficiencies. The court directed the clerk to close the case. Judge Phyllis J. Hamilton signed the order on June 13, 2023.