Bonilla v. Segerstrom
- Phyllis Hamilton
- 4:20-cv-08025
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Aronson, Judge Hamilton dismissed the related cases with prejudice after finding no imminent danger and additional legal bars.
Steven Wayne Bonilla’s multiple related civil-rights cases were dismissed with prejudice and closed; pending motions were terminated and later documents in those cases were to be returned without filing.
What happened
In Steven Wayne Bonilla v. Brian Ross Aronson, et al., Bonilla, a state prisoner representing himself, filed many nearly identical civil-rights lawsuits. He challenged his conviction and the handling of his petitions and other cases by state and federal courts.
The court said Bonilla was barred from filing without paying the required fees unless he faced imminent danger of serious physical injury when he filed. The allegations did not show such danger. The court also said that, even if he could proceed without paying fees, several legal rules barred his lawsuits.
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 those closed cases without filing them.
The detailed version
- Bonilla v. Segerstrom · No. 4:20-cv-08025
- Phyllis Hamilton
- Dec. 1, 2020
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The opinion addresses numerous related cases, including case numbers 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 complaints were nearly identical. Bonilla sought relief concerning his underlying conviction and the handling of his self-filed petitions and other cases by state and federal courts. The opinion also notes that he had a pending federal petition challenging his custody with appointed counsel and was represented by counsel in state-court proceedings.
Court’s Analysis
Bonilla sought, or potentially sought, permission to proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has previously brought qualifying unsuccessful lawsuits generally may not proceed without paying the fees unless he shows that he was in imminent danger of serious physical injury when the complaint was filed. The court stated that Bonilla had already been disqualified from proceeding without paying under that provision.
The court found that the allegations did not show imminent danger at the time of filing. It therefore concluded that Bonilla could not proceed without paying the filing fees. The court further stated that, even if permission to proceed without paying fees were granted, the lawsuits would be barred under several legal doctrines and precedents: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court.
Disposition
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 additional documents Bonilla submitted in the closed cases.
This was a procedural disposition based on Bonilla’s inability to proceed without paying the filing fees and the stated legal bars; the opinion did not decide the underlying validity of his conviction or the other claims on their merits. Judge Phyllis J. Hamilton signed the order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.