Joseph Aruanno v. IRS

CourtCourt of Appeals for the Third Circuit
DecidedFebruary 20, 2024
Docket23-2630
StatusUnpublished

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Bluebook
Joseph Aruanno v. IRS, (3d Cir. 2024).

Opinion

CLD-057 NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT ___________

No. 23-2630 ___________

JOSEPH ARUANNO, Appellant

v.

INTERNAL REVENUE SERVICE ____________________________________

On Appeal from the United States District Court for the District of New Jersey (D.C. Civil Action No. 2:23-cv-00786) District Judge: Honorable Evelyn Padin ____________________________________

Submitted for Possible Summary Action Pursuant to Third Circuit LAR 27.4 and I.O.P. 10.6 January 18, 2024 Before: KRAUSE, FREEMAN, and SCIRICA, Circuit Judges

(Opinion filed: February 20, 2024) _________

OPINION * _________

PER CURIAM

Joseph Aruanno is a frequent pro se litigant who, since 2005, has been civilly

* This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not constitute binding precedent. committed in New Jersey under the New Jersey Sexually Violent Predator Act

(“SVPA”). In 2022, he sought to file an in forma pauperis (“IFP”) complaint against the

IRS and the New Jersey Department of Corrections in the United States District Court for

the Northern District of California (“the Northern District Court”). He cited Scholl v.

Mnuchin, N.D. Cal. Civ. No. 20-cv-05309, in which the Northern District Court had

granted a preliminary injunction to enjoin the Department of the Treasury and its

Secretary, the IRS and its Commissioner, and the United States from excluding

incarcerated persons from receiving economic impact payments (“stimulus checks”)

under the Coronavirus Aid, Relief, and Economic Security Act. See Scholl v. Mnuchin,

494 F. Supp. 3d 661 (N.D. Cal. 2020). He sought to bring to the court’s attention that

some prisons, including the facility where he was detained, were keeping the stimulus

checks instead of giving them to the incarcerated persons, in his case on the basis of the

belief that he owed the facility money. He asked, inter alia, that the facility be directed to

return the funds to the IRS and that the IRS be directed not to mail any funds to him at

the facility.

Before ruling on Aruanno’s IFP motion, the Northern District Court transferred his

case to the United States District Court for the District of New Jersey (“the District

Court”), explaining that venue was proper there because Aruanno’s claim “involves

entirely different defendants located in the District of New Jersey.” ECF No. 4 at 2 (also

citing 28 U.S.C. § 1406(a)). To the extent that Aruanno had been seeking to join his case

to Scholl, his request was denied.

Upon the transfer, the District Court directed Aruanno to show cause why it

2 should not deny his IFP application given his history of abusive litigation. 1 In response,

Aruanno stated, as preliminary matter, that a legal guardian had to be appointed for him

before the case could proceed. He also asked that his case be transferred back to

Northern District of California, arguing that it belonged there, where the lead plaintiff in

Scholl had been granted IFP status and the IRS is the “lead defendant” in his case. ECF

No. 7 at 3. And he stated that he is innocent and subject to an invalid civil commitment

order, which has exposed him to much harm (including, most recently, the theft of his

stimulus checks) for which he has sought relief by filing legal actions. The District Court

denied Aruanno’s IFP application as well as his requests for a guardian ad litem and a

transfer. Aruanno appeals. 2

We have jurisdiction under 28 U.S.C. § 1291 to review the order denying

Aruanno’s IFP motion. See Deutsch v. United States, 67 F.3d 1080, 1083 (3d Cir. 1995)

(concluding that such an order is “in essence final” for purposes of § 1291). And,

because the District Court entered a final judgment, “[w]e have the power to review [its]

1 The District Court noted the “three strikes” provision of the Prison Litigation Reform Act, 28 U.S.C. § 1915(g). Under that provision, prisoners who have had three or more actions dismissed as frivolous or malicious or for failure to state a claim may not proceed IFP unless they show that they are “under imminent danger of serious physical injury.” Id. However, the District Court did not apply the statute to Aruanno after concluding that Aruanno “is not a prisoner within the meaning of § 1915(g).” ECF No. 8 at 5. See also, e.g., Jones v. Cuomo, 2 F.4th 22, 26 (2d Cir. 2021) (collecting cases that hold that civilly committed sexual offenders are not “prisoners” under this definition), cert. denied, 142 S. Ct. 1141 (2022). 2 We previously granted Aruanno’s application to proceed IFP on appeal. At that time, we notified him that his case would be considered for possible summary action. We may take summary action if no substantial issue is presented on appeal. See 3d Cir. L.A.R. 27.4; 3d Cir. I.O.P. 10.6. 3 transfer order,” In re McGraw-Hill Glob. Educ. Holdings LLC, 909 F.3d 48, 55 (3d Cir.

2018), and its order denying the appointment of a guardian ad litem, see generally In re

Pressman-Gutman Co., Inc., 459 F.3d 383, 397-98 & n.12 (3d Cir. 2006).

First, we review the District Court’s transfer decision for abuse of discretion. See

Jumara v. State Farm Ins., 55 F.3d 873, 878 (3d Cir. 1995). We recognize, as Aruanno

pointed out to the District Court, that the Northern District Court made a mistake in

concluding that Aruanno’s complaint related to “entirely different defendants” than those

involved in Scholl. The IRS is a defendant in both actions. However, Aruanno also sued

the New Jersey Department of Corrections and, as the District Court noted, included

allegations about how his stimulus checks were redirected by that defendant to pay down

debts to it that he claims that he did not owe. Given that those claims are distinct from

what is at issue in Scholl and related to the actions of a defendant in the District of New

Jersey (where Aruanno is being held), we cannot say that Aruanno’s case belonged in the

Northern District of California instead of in the District Court. See generally Coffey v.

Van Dorn Iron Works, 796 F.2d 217, 219–20 (7th Cir. 1986) (discussing how a district

judge must consider the statutory factors in light of all the circumstances of the case” in

the context of a transfer under 28 U.S.C. § 1404(a)); see also Van Dusen v. Barrack, 376

U.S. 612, 622-24 & n.11 (1964) (interpreting § 1404(a) but also describing “analogous

provisions of §1406(a), which shares the same statutory context” with § 1404(a)). We

conclude that the District Court did not abuse its discretion in denying Aruanno’s request

to transfer the case back to the Northern District of California.

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