Bonilla v. Givens
- Phyllis Hamilton
- 4:20-cv-08002
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Aronson, Judge Hamilton dismissed the state prisoner’s multiple civil-rights cases with prejudice because he was not in imminent danger and his lawsuits were 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 to return later submissions without filing them.
What happened
In Bonilla v. Aronson, Steven Wayne Bonilla, a state prisoner, filed multiple similar civil-rights lawsuits without a lawyer. He challenged his conviction and the way state and federal courts handled his other petitions and cases.
The court ruled that Bonilla could not proceed without paying the required filing fees because his allegations did not show that he faced an immediate risk of serious physical injury when he filed. The court also said that, even if he had been allowed to proceed without paying, the lawsuits were barred by several legal rules concerning challenges to convictions, ongoing state proceedings, and court decisions.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, and closed the cases. The clerk was ordered to return any further documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Givens · No. 4:20-cv-08002
- Phyllis Hamilton
- Dec. 1, 2020
Background
Steven Wayne Bonilla, 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 and the handling of his various petitions and other cases by state and federal courts. The order addressed the listed cases, which included multiple case numbers.
Court’s analysis
The court stated that Bonilla had been disqualified from proceeding in forma pauperis, meaning without prepaying the filing fee, under 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 danger.
The court further stated that, even if Bonilla had been allowed to proceed without prepaying the filing fee, his lawsuits would be barred under the legal rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order did not provide a separate merits determination of Bonilla’s underlying conviction-related allegations.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases.
Names and case identification
The supplied metadata calls the matter “Bonilla v. Givens,” but the opinion’s caption identifies the defendants as “Brian Ross Aronson, et al.” This summary follows the opinion’s caption.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.