Bonilla v. Arnold
- Phyllis Hamilton
- 4:20-cv-07868
- U.S. District Court · Northern District of California
- 2
Judge Hamilton dismissed Bonilla v. Aronson with prejudice because Bonilla could not proceed without fees and his claims were legally barred.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice. The order also terminated pending motions, closed the cases, and directed the clerk not to file further documents Bonilla submitted in them.
What happened
In Bonilla v. Aronson, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights lawsuits. He challenged his conviction and the handling of his other court cases and petitions.
The court said Bonilla could not proceed without paying the filing fee because he had previously been disqualified from that status and had not shown an immediate risk of serious physical harm when he filed. The court also said the lawsuits would be barred even if that status 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 future documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Arnold · No. 4:20-cv-07868
- Phyllis Hamilton
- Dec. 1, 2020
Background
Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights complaints under 42 U.S.C. § 1983. 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 said the complaints were nearly identical. Bonilla sought relief concerning his underlying conviction and the handling of his self-represented petitions and other cases in state and federal courts. The order also noted that he had a pending federal petition with appointed counsel and was represented by counsel in state proceedings.
Reasons for dismissal
The court addressed Bonilla's possible request 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 was in immediate danger of serious physical injury when he filed the complaint. The court found that Bonilla's allegations did not show that danger. It therefore concluded that he could not proceed without paying the filing fee.
The court further stated that, even if an application to proceed without paying the filing fee 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 did not provide a separate claim-by-claim analysis of which cited bar applied to which complaint.
Ruling and case status
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also directed the clerk to return, without filing, any further 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.