Bonilla v. Day
- Phyllis Hamilton
- 4:20-cv-07968
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Aronson, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying and his claims were barred.
Steven Wayne Bonilla’s multiple self-represented civil-rights cases were dismissed with prejudice. The order also directed the clerk to terminate pending motions, close the cases, and return future filings submitted in them without filing.
What happened
In Bonilla v. Aronson, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits challenging his conviction and the handling of other cases.
The court ruled that Bonilla could not proceed without paying the filing fees because he did not show an immediate serious physical danger when he filed. The court also said that, even if he could proceed without paying, the lawsuits were barred by several legal doctrines. It dismissed the cases with prejudice, ended all pending motions, and closed the cases.
Judge Phyllis J. Hamilton issued the order on December 1, 2020.
The detailed version
- Bonilla v. Day · No. 4:20-cv-07968
- Phyllis Hamilton
- Dec. 1, 2020
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 while representing himself. The complaints were described as nearly identical. They sought relief concerning Bonilla’s underlying conviction and the handling of his various self-represented habeas petitions and other cases by state and federal courts.
The order lists multiple related case numbers, including 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.
Reasons for dismissal
The court explained that Bonilla had been barred from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless he showed that he faced an imminent danger of serious physical injury when he filed the complaint. The court found that the allegations did not show such danger. As a result, Bonilla could not proceed without paying the filing fee.
The court further stated that, even if an application to proceed without paying the 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 did not provide a separate claim-by-claim analysis of which doctrine applied to which complaint.
Ruling
Judge Phyllis J. Hamilton dismissed the cases with prejudice. The clerk was directed to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any further documents Bonilla submitted in the closed cases.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.