Bonilla v. Kaufman
- Phyllis Hamilton
- 4:20-cv-08005
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Aronson, Judge Hamilton dismissed multiple civil-rights cases with prejudice, finding no imminent danger and concluding legal barriers also barred them.
Steven Wayne Bonilla and the defendants in the multiple listed civil-rights cases. The cases were dismissed with prejudice, closed, and subject to the clerk's direction to return later submissions without filing them.
What happened
In Bonilla v. Aronson, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights complaints under a federal law allowing suits against state officials. The complaints challenged his conviction and the handling of his other cases and petitions.
The court found that Bonilla could not proceed without paying the filing fees because he had not shown that he faced imminent danger of serious physical injury when he filed. The court also said that, even if he could proceed without those fees, the lawsuits would be barred by other legal rules. It dismissed the cases with prejudice, closed them, terminated pending motions, and directed the clerk to return later submissions without filing them.
Judge Phyllis J. Hamilton entered the order on December 1, 2020. The order did not decide the underlying conviction-related claims on their merits.
The detailed version
- Bonilla v. Kaufman · No. 4:20-cv-08005
- Phyllis Hamilton
- Dec. 1, 2020
Background
Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights complaints under 42 U.S.C. § 1983. The complaints sought relief concerning his underlying conviction and the handling of his self-filed habeas petitions and other cases by state and federal courts. The opinion also notes that Bonilla had a pending federal habeas petition in the same court with appointed counsel and was represented by counsel in state habeas proceedings.
Filing-fee status
Bonilla had been disqualified from proceeding without paying the filing fee under the Prison Litigation Reform Act's three-strikes provision, 28 U.S.C. § 1915(g), unless he showed that he was in imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such imminent danger. As a result, Bonilla could not proceed without paying the filing fee.
Other legal bars
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 analyze each of those rules or explain which rule applied to which complaint.
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 further documents Bonilla submitted in the closed cases. The order was signed by United States District Judge Phyllis J. Hamilton.
Classification
This is a procedural order because the court disposed of the cases based on eligibility to proceed without paying filing fees and stated legal bars, rather than deciding the underlying conviction-related claims on their merits.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.