Bonilla v. Johnson
- Phyllis Hamilton
- 4:20-cv-08004
- U.S. District Court · Northern District of California
- 2
Bonilla v. Aronson: Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without prepaying filing fees and the suits were legally barred.
Steven Wayne Bonilla, whose multiple civil-rights cases were dismissed with prejudice; the defendants in those cases; and the clerk’s office, which was ordered to close the cases and return later submissions without filing them.
What happened
Bonilla v. Aronson involved multiple complaints by Steven Wayne Bonilla, a state prisoner proceeding without a lawyer under a federal civil-rights law. The complaints were nearly identical and sought relief concerning his conviction and the handling of his other state and federal cases.
The court said Bonilla was barred from proceeding without prepaying filing fees unless he showed that he faced an immediate serious physical danger when he filed. The court found that his complaints did not show such danger. It also said that, even if he had been allowed to proceed without prepaying fees, the lawsuits would be barred under several legal rules and earlier decisions cited in the order.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, and closed the cases. The clerk was instructed to return any further documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Johnson · No. 4:20-cv-08004
- Phyllis Hamilton
- Dec. 1, 2020
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple nearly identical civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The listed cases include multiple docket numbers in the Northern District of California. The order states that Bonilla is a condemned prisoner with a pending federal petition challenging his detention or conviction in that court, where he has appointed counsel. It also states that he is represented by counsel in state-court proceedings concerning that petition.
The complaints sought relief concerning Bonilla’s underlying conviction and the handling of his various filings seeking review of his conviction or detention, as well as other cases handled by state and federal courts.
Proceeding Without Prepaying Filing Fees
The court addressed whether Bonilla could proceed without prepaying the filing fees. Under 28 U.S.C. § 1915(g), the court said Bonilla had previously been disqualified from proceeding without prepaying fees unless he showed that he was in immediate danger of serious physical injury when he filed the complaint. The court found that the allegations in these complaints did not show that he faced such danger at the relevant time.
Other Bars Identified by the Court
The court further stated that, even if Bonilla had been allowed to proceed without prepaying filing fees, the lawsuits would be barred under Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order did not separately analyze each cited authority or identify which bar applied to each 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 additional documents Bonilla submitted in the closed cases. This was a procedural disposition because the court dismissed the cases based on filing-fee eligibility and legal bars rather than deciding the underlying civil-rights claims on their merits.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.