Bonilla v. Penney
- Phyllis Hamilton
- 4:20-cv-08024
- U.S. District Court · Northern District of California
- 2
Bonilla v. Aronson: Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying and his claims were legally barred.
Steven Wayne Bonilla's multiple civil-rights cases against Brian Ross Aronson and the other named defendants were dismissed with prejudice; the clerk was directed to close the cases and return later submissions without filing them.
What happened
In Bonilla v. Aronson, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights cases under a federal civil-rights law. He challenged his conviction and the handling of his other court cases.
Bonilla had previously been barred from proceeding without paying the filing fee unless he faced imminent danger of serious physical injury. The court found that his complaints did not show such danger. The court also stated that the lawsuits would be barred by several legal rules even if he could proceed without paying.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, directed the clerk to terminate all pending motions and close the cases, and ordered the clerk to return future documents submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Penney · No. 4:20-cv-08024
- Phyllis Hamilton
- Dec. 1, 2020
Background
Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The complaints were nearly identical. They 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 custody in the same court, with appointed counsel, and was represented by counsel in state-court proceedings.
Filing-fee status
Bonilla had been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless he was in imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show imminent danger at that time. Therefore, Bonilla could not proceed without paying the filing fee.
Other grounds for dismissal
The court further ruled that, even if Bonilla's applications to proceed without paying had been granted, the lawsuits would be barred under the legal rules identified 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 explain how each cited rule applied to each individual case.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also ordered the clerk to return, without filing, any further documents Bonilla submitted in the closed cases. The order was signed by United States District Judge Phyllis J. Hamilton.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.