Bonilla v. Ryan
- Phyllis Hamilton
- 4:20-cv-08223
- U.S. District Court · Northern District of California
- 2
Bonilla v. Aronson: Judge Hamilton dismissed the prisoner’s multiple civil-rights cases with prejudice because he could not proceed without paying filing fees.
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 future submissions in those cases without filing them.
What happened
In Bonilla v. Aronson and related cases, Steven Wayne Bonilla, a state prisoner representing himself, filed nearly identical civil-rights complaints about his conviction and how courts handled his other cases. The complaints were brought under a federal civil-rights law.
The court said Bonilla was barred from proceeding without paying filing fees unless he showed an immediate danger of serious physical injury. The court found that his complaints did not show such danger. It also said that, even if he could proceed without paying, the lawsuits would be barred by other legal rules concerning challenges to convictions, ongoing state proceedings, and federal court proceedings.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and closed the cases. The clerk was instructed to return future filings in those closed cases without filing them.
The detailed version
- Bonilla v. Ryan · No. 4:20-cv-08223
- Phyllis Hamilton
- Dec. 1, 2020
Background
Steven Wayne Bonilla, identified by the court as a state prisoner, filed multiple complaints representing himself under 42 U.S.C. § 1983, a federal law that allows claims for certain violations of constitutional rights by persons acting under state law. The court said the complaints were nearly identical and sought relief concerning Bonilla’s underlying conviction or the way state and federal courts had handled his self-filed petitions and other cases.
The opinion also stated that Bonilla had a pending federal petition challenging his custody in the same court with appointed counsel, and that he was represented by counsel in state court proceedings. Those proceedings were mentioned as background to the court’s treatment of the new civil-rights cases.
Filing-fee status
The court addressed Bonilla’s possible requests to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), the court said he had previously been disqualified from proceeding without paying 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. It therefore ruled that Bonilla could not proceed without paying the filing fee.
Other stated barriers
The court further stated that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under the rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not separately analyze each rule in detail; it cited them as additional reasons the lawsuits could not proceed.
Disposition
The court dismissed the cases with prejudice. It also ordered 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. Because the order disposed of the cases through filing-fee restrictions and other threshold barriers rather than deciding the underlying civil-rights claims, this is a procedural order. Judge Phyllis J. Hamilton signed the order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.