Bonilla v. Blum
- Phyllis Hamilton
- 4:20-cv-07965
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Aronson, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla showed no imminent danger and his claims faced legal bars.
Steven Wayne Bonilla’s multiple civil-rights lawsuits were dismissed with prejudice. The order also affected the defendants named in those cases by closing the actions without allowing them to proceed.
What happened
Steven Wayne Bonilla, a condemned state prisoner, filed multiple similar lawsuits without a lawyer against Brian Ross Aronson and others. He challenged his conviction and how state and federal courts handled his other cases.
The court ruled that Bonilla could not proceed without paying the filing fee because his allegations did not show that he faced imminent danger of serious physical injury when he filed. The court also said the lawsuits would be barred even if he were allowed to proceed without paying.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, closed the cases, and ordered the clerk to return later documents without filing them.
The detailed version
- Bonilla v. Blum · No. 4:20-cv-07965
- Phyllis Hamilton
- Dec. 1, 2020
Background
Steven Wayne Bonilla, a state prisoner sentenced to death, filed multiple similar complaints without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute for claims against state actors. The complaints sought relief concerning Bonilla’s underlying conviction and the handling of his other petitions and cases in state and federal court. The opinion states that Bonilla had a pending federal petition challenging his conviction with appointed counsel and was also represented by counsel in state-court proceedings.
Filing-fee status
Bonilla was disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), which generally bars a prisoner with qualifying prior dismissals from proceeding without payment unless the prisoner shows that he faced imminent danger of serious physical injury when the complaint was filed. The court found that the allegations did not show imminent danger at that time.
Other grounds identified by the court
The court further stated that, even if Bonilla’s applications to proceed without paying were granted, the lawsuits would be barred under the legal rules discussed in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion does not separately analyze each complaint or explain which cited rule applies to which claim.
Ruling
The court dismissed the listed cases with prejudice. It directed the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in those closed cases. Judge Phyllis J. Hamilton signed the order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.