Bonilla v. Barley
- Phyllis Hamilton
- 4:20-cv-07964
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Aronson, Judge Hamilton dismissed multiple federal civil-rights cases with prejudice because Bonilla could not proceed without paying and his claims were barred.
Steven Wayne Bonilla's multiple listed civil-rights cases were dismissed with prejudice. The defendants were affected because those cases were closed, and the clerk was directed to return Bonilla's further submissions in them without filing.
What happened
Bonilla v. Aronson involved multiple civil-rights cases filed by Steven Wayne Bonilla, a state prisoner representing himself. The complaints were nearly identical and sought relief concerning his conviction and the handling of his other court cases and petitions.
The court said Bonilla was barred from proceeding without paying the filing fee unless he showed an immediate danger of serious physical injury when he filed. The court found that his allegations did not show such danger. It also said that, even if he could proceed without paying, the lawsuits would be barred under several 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. Barley · No. 4:20-cv-07964
- Phyllis Hamilton
- Dec. 1, 2020
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints while representing himself under 42 U.S.C. § 1983, a federal law that permits certain claims against government actors. The order lists multiple related case numbers. The complaints were nearly identical and sought relief concerning Bonilla's underlying conviction, his self-represented petitions for release from custody, and the handling of other cases by state and federal courts.
The order states that Bonilla had a pending federal petition challenging his custody in the same court, with appointed counsel, and was also represented by counsel in state-court proceedings concerning his custody.
Court's analysis
The court addressed Bonilla's ability to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from that status may proceed without paying only if he shows that he was in immediate danger of serious physical injury when he filed the complaint. The court found that Bonilla's allegations did not show such danger.
The court further stated that, even if Bonilla's applications to proceed without paying were granted, the lawsuits would be barred under Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The order does not provide a separate claim-by-claim explanation of which cited rule applied to which case.
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 further documents Bonilla submitted in the closed cases. The order was signed by Judge Phyllis J. Hamilton.
Procedural significance
This was a procedural disposition rather than a decision on the underlying civil-rights claims. The court relied on Bonilla's inability to proceed without paying and on threshold legal bars, without deciding the merits of each claim.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.