Bonilla v. Mayfied
- Phyllis Hamilton
- 4:20-cv-08224
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Aronson, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and additional legal bars.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The clerk was directed to close the cases, terminate pending motions, and return without filing any further documents submitted in them.
What happened
Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights lawsuits without a lawyer. His complaints sought relief concerning his conviction and the handling of his state and federal petitions and other cases. The cases were captioned Bonilla v. Brian Ross Aronson, et al., and related matters.
The court said Bonilla had previously been barred from proceeding without paying the filing fee unless he showed that he faced an immediate danger of serious physical injury when he filed. The court found that his complaints did not show that danger. It also said that, even if he could proceed without paying the fee, the lawsuits would be barred by several legal rules and prior decisions.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, meaning the dismissals ended these cases and the court used that term expressly. The clerk was ordered to terminate pending motions, close the cases, and return without filing any further documents Bonilla submitted in them.
The detailed version
- Bonilla v. Mayfied · No. 4:20-cv-08224
- Phyllis Hamilton
- Dec. 1, 2020
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple pro se civil-rights complaints under 42 U.S.C. § 1983. The complaints were nearly identical. They sought relief concerning Bonilla’s underlying conviction, the handling of his pro se habeas petitions, and the handling of other state and federal court cases. The opinion also states that Bonilla had a pending federal habeas petition in the same court with appointed counsel and was represented by counsel in state habeas proceedings.
Proceeding Without Paying the Filing Fee
The court addressed Bonilla’s requests, or possible requests, to proceed in forma pauperis, which means proceeding without paying the filing fee. Under 28 U.S.C. § 1915(g), the court stated that Bonilla had been disqualified from proceeding in that manner unless he was facing imminent danger of serious physical injury when he filed the complaint. The court found that the allegations did not show imminent danger at the time of filing. Therefore, Bonilla could not proceed in forma pauperis.
Other Legal Bars
The court further stated that, even if an application to proceed in forma pauperis 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 opinion does not explain in detail how each cited rule or decision applied to each individual complaint.
Disposition
The court dismissed the cases with prejudice. It ordered 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.