Bonilla v. Byrd
- Phyllis Hamilton
- 4:20-cv-07966
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Aronson, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla did not meet the emergency exception and his claims faced legal barriers.
Steven Wayne Bonilla and the related cases listed in the order. The cases were dismissed with prejudice, pending motions were terminated, and future documents submitted in those closed cases were to be returned without filing.
What happened
In Bonilla v. Aronson and related cases, Steven Wayne Bonilla, a state prisoner representing himself, filed nearly identical civil-rights lawsuits. He sought relief concerning his conviction and the handling of his other state and federal court cases.
The court said Bonilla could not proceed without paying the filing fee because he had previously been barred from that status unless he faced an immediate risk of serious physical injury. The complaints did not show such a risk. The court also said the lawsuits would be barred by legal rules that limit challenges to convictions and interfere with ongoing state proceedings, among other grounds.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, closed the cases, and directed the clerk to return any further documents Bonilla submitted in them without filing them.
The detailed version
- Bonilla v. Byrd · No. 4:20-cv-07966
- Phyllis Hamilton
- Dec. 1, 2020
Background
Steven Wayne Bonilla, a state prisoner sentenced to death, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The order covers the lead case and related cases listed in the caption. Bonilla also had a pending federal petition challenging his custody, with appointed counsel, and was represented by counsel in state-court proceedings concerning that petition.
The complaints were nearly identical. They sought relief related to Bonilla’s underlying conviction and to the handling of his various self-filed petitions and other cases in state and federal courts.
Court’s Analysis
The court addressed Bonilla’s possible requests to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has had qualifying prior cases generally cannot proceed without prepaying the fee unless he was facing an immediate danger of serious physical injury when he filed the complaint. The court found that the allegations did not show that Bonilla faced such danger at the relevant time.
The court further stated that, even if Bonilla’s requests to proceed without prepaying the fee were granted, the lawsuits would be barred under several legal doctrines and authorities, including rules concerning challenges to criminal convictions, interference with ongoing state proceedings, and certain claims against federal courts or judges. The opinion cites Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court.
Disposition
Judge Phyllis J. Hamilton ordered that the cases be dismissed with prejudice. The clerk was directed to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any further documents Bonilla submitted in the closed cases.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.