Alexander Harrison West v. Internal Revenue Service

Summary

The court screened Alexander Harrison West’s amended pro se complaint against the Internal Revenue Service and concluded that the asserted ADA, Rehabilitation Act, tort, and Privacy Act claims were subject to dismissal for sovereign-immunity, jurisdictional, pleading, or defendant-status deficiencies. The court permitted West to file a second amended complaint by May 4, 2026, and continued the temporary waiver of the filing fee pending further screening.

Holdings

1. The IRS was entitled to sovereign immunity from West's ADA claims because the ADA provisions at issue do not apply to the United States or its agencies, and from his Rehabilitation Act § 504 claim because he sought only monetary damages and had not identified an applicable waiver.
2. West's tort claims were subject to dismissal because the IRS is not a proper defendant under the Federal Tort Claims Act and West did not allege exhaustion of the FTCA's administrative-claim requirement.
3. West failed to state a Privacy Act claim because his allegation of unauthorized disclosure was wholly conclusory and did not identify who disclosed what information to whom or in what context.
4. The court permitted West to file a second amended complaint by May 4, 2026, subject to the stated pleading and screening requirements.

Questions Presented

1. Whether the IRS is protected by sovereign immunity from West's ADA and Rehabilitation Act claims seeking monetary damages.
2. Whether West's tort claims could proceed against the IRS under the Federal Tort Claims Act without naming the United States and alleging exhaustion of administrative remedies.
3. Whether West stated a claim under the Privacy Act based on an allegation of unauthorized disclosure of information.
4. Whether West should be permitted to file a second amended complaint to cure the identified deficiencies.

Disposition

other