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N.D. Cal.Procedural orderFiled Dec. 1, 2020

Bonilla v. Kalpacoff

Judge
Phyllis Hamilton
Docket
4:20-cv-08007
Court
U.S. District Court · Northern District of California
Pages
2
Civil RightsSection 1983Pro SeCivil Procedure
In one sentence

In Bonilla v. Aronson, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without filing-fee relief and the claims were barred.

Who this affects

Steven Wayne Bonilla and the defendants in his multiple civil-rights cases; the cases were dismissed with prejudice and closed.

What happened

In Bonilla v. Aronson, Steven Wayne Bonilla, a state prisoner, filed multiple similar civil-rights cases without a lawyer. He sought relief concerning his conviction and the handling of his state and federal court cases.

The court said Bonilla was barred from proceeding without paying filing fees unless he showed an immediate danger of serious physical injury when he filed. The complaints did not show that danger. The court also said the lawsuits would be barred even if fee relief were granted, citing several legal doctrines and decisions.

Judge Phyllis J. Hamilton dismissed the cases with prejudice, ordered the clerk to end all pending motions and close the cases, and directed the clerk to return future filings in those closed cases without filing them.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Bonilla v. Kalpacoff · No. 4:20-cv-08007
Judge
Phyllis Hamilton
Date
Dec. 1, 2020

Background

Steven Wayne Bonilla filed multiple nearly identical complaints under 42 U.S.C. § 1983, a federal law allowing civil-rights claims against people acting under state law. The opinion identifies Bonilla as a state prisoner and says he was proceeding without a lawyer in these cases. He is a condemned prisoner with a pending federal petition challenging his custody, for which he has appointed counsel, and he is also represented by counsel in state-court proceedings.

The complaints sought relief concerning Bonilla’s underlying conviction and the handling of his various petitions and other cases by state and federal courts. The opinion lists multiple case numbers, including 20-cv-07866-PJH and numerous other cases.

Filing-fee status and claimed barriers

The court stated that Bonilla had previously been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying the filing fee unless he was facing an imminent danger of serious physical injury when he filed the complaint. The court found that the allegations did not show such danger at the relevant time.

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 opinion does not separately explain which cited doctrine applies to which complaint.

Disposition

The court dismissed the cases with prejudice. It also ordered the clerk to terminate all pending motions and close the cases, and directed the clerk to return, without filing, any further documents Bonilla submitted in the closed cases. Judge Phyllis J. Hamilton signed the order.

Classification rationale

This is a procedural order. The court disposed of the cases based on the filing-fee restriction and asserted legal barriers rather than deciding the underlying civil-rights claims on their merits.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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