Bonilla v. Aronson
- Phyllis Hamilton
- 4:20-cv-07866
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Aronson, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying and his claims were barred.
Steven Wayne Bonilla and the defendants named in his multiple civil-rights cases.
What happened
In Bonilla v. Aronson, Steven Wayne Bonilla, a condemned state prisoner representing himself, filed multiple nearly identical civil-rights cases. He challenged his conviction and the way state and federal courts handled his other petitions and cases.
The court said Bonilla could not proceed without paying the filing fees because he had previously been barred from proceeding without payment unless he showed an immediate danger of serious physical injury. The court found that his complaints did not show such a danger. It also said that, even if he were allowed to proceed without paying, the lawsuits would be barred by other legal rules.
The court dismissed the cases with prejudice, ended all pending motions, and closed the cases. Judge Phyllis J. Hamilton also directed the clerk to return any further documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Aronson · No. 4:20-cv-07866
- Phyllis Hamilton
- Dec. 1, 2020
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983, a federal law allowing certain claims against state actors for violating federal rights. The order covers the case numbers listed in the caption, including 20-cv-07866-PJH, 20-cv-07867-PJH, 20-cv-07868-PJH, 20-cv-07963-PJH, 20-cv-07964-PJH, 20-cv-07965-PJH, 20-cv-07966-PJH, 20-cv-07968-PJH, 20-cv-07971-PJH, 20-cv-08002-PJH, 20-cv-08004-PJH, 20-cv-08005-PJH, 20-cv-08006-PJH, 20-cv-08007-PJH, 20-cv-08008-PJH, 20-cv-08024-PJH, 20-cv-08025-PJH, 20-cv-08026-PJH, 20-cv-08220-PJH, 20-cv-08221-PJH, 20-cv-08222-PJH, 20-cv-08223-PJH, 20-cv-08224-PJH, and 20-cv-08225-PJH.
The court described the complaints as nearly identical. Bonilla sought relief concerning his underlying conviction and the handling of various petitions and other cases by state and federal courts. The order also noted that he had a pending federal petition challenging his custody with appointed counsel and was represented by counsel in state-court proceedings.
Reasoning
The court stated that Bonilla had been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless he was in immediate danger of serious physical injury when he filed the complaint. The court found that the allegations did not show such danger, so he could not proceed without paying.
The court further stated that, even if an application to proceed without paying were granted, the lawsuits would be barred under the rules discussed in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order did not assign a separate rule to each complaint or claim.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions, close the cases, and return without filing any further documents Bonilla submitted in those closed cases. Judge Phyllis J. Hamilton signed the order on December 1, 2020. The order disposed of the cases on filing-status and other threshold grounds rather than deciding the underlying civil-rights claims on their merits.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.