Bonilla v. Skillman
- Phyllis Hamilton
- 4:20-cv-08026
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Aronson, Judge Hamilton dismissed multiple prisoner civil-rights cases with prejudice after finding no imminent danger and procedural barriers.
Steven Wayne Bonilla's multiple civil-rights cases and the defendants named in those cases were affected; the cases were dismissed with prejudice and closed.
What happened
Steven Wayne Bonilla, a state prisoner, filed multiple similar civil-rights lawsuits without a lawyer. His complaints sought relief concerning his conviction and the handling of his other state and federal cases.
The court said Bonilla could not proceed without paying the filing fees because he had previously been disqualified from that option, and his complaints did not show that he faced an immediate danger of serious physical injury when he filed them. The court also said the lawsuits would be barred even if that filing-fee request were granted.
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. Skillman · No. 4:20-cv-08026
- Phyllis Hamilton
- Dec. 1, 2020
Background
Steven Wayne Bonilla filed multiple, nearly identical civil-rights complaints under 42 U.S.C. § 1983. The opinion identifies him as a state prisoner and says he had a pending federal petition challenging his custody with appointed counsel, as well as representation in state-court proceedings. His civil-rights complaints sought relief concerning his underlying conviction and the handling of various petitions and other cases by state and federal courts.
Filing-fee issue
Bonilla sought, or could have sought, permission to proceed without paying the filing fees. The court said he had been disqualified from using that procedure under the three-strikes provision of 28 U.S.C. § 1915(g), unless he showed that he was in imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger, so Bonilla could not proceed without paying the fees.
Other grounds for dismissal
The court further ruled that, even if Bonilla’s request to proceed without paying fees were granted, the lawsuits would be barred under the legal rules identified in the opinion: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not provide a separate claim-by-claim analysis of those grounds.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases, and to return without filing any additional documents Bonilla submitted in the closed cases. Judge Phyllis J. Hamilton signed the order on December 1, 2020.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.