Bonilla v. White
- Phyllis Hamilton
- 4:24-cv-04623
- U.S. District Court · Northern District of California
- 2
In Bonilla v. White, Judge Hamilton dismissed three civil-rights cases with prejudice because Bonilla could not proceed without the filing fee and his claims were barred.
Steven Wayne Bonilla’s three 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 closed cases without filing them.
What happened
In Bonilla v. White, Steven Wayne Bonilla, a state prisoner, filed three nearly identical civil-rights cases against various federal and state judges. He sought relief related to his conviction and the handling of his other court cases.
The court said Bonilla had previously been barred from proceeding without paying the filing fee unless he showed that he faced an immediate danger of serious physical injury. The complaints did not show such a danger when they were filed. The court also said that, even if he could proceed without paying the fee, the lawsuits were barred by rules and precedents concerning challenges to convictions, ongoing state proceedings, and interference with other courts.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and ordered the clerk to close the cases and return any further filings without filing them. The court also rejected the request to question the judge’s impartiality based on Bonilla’s repetitive filings.
The detailed version
- Bonilla v. White · No. 4:24-cv-04623
- Phyllis Hamilton
- Aug. 27, 2024
Background
Steven Wayne Bonilla, a state prisoner, filed three nearly identical complaints under 42 U.S.C. § 1983, the federal civil-rights statute that permits claims against state actors for constitutional violations. He named various federal and state judges as defendants. The complaints sought relief concerning Bonilla’s underlying conviction and the way other state and federal cases had been handled.
The opinion states that Bonilla was a condemned prisoner with a pending federal petition challenging his imprisonment in the same court, where he had appointed counsel. It also states that he was represented by counsel in related state proceedings.
Proceeding Without the Filing Fee
The court explained that Bonilla had been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless he showed that he was under imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger at the relevant time.
Other Bars to the Lawsuits
The court further ruled that, even if Bonilla’s applications to proceed without paying the filing fee were granted, the lawsuits would be barred under authorities addressing challenges to criminal convictions, interference with ongoing state proceedings, and restrictions on lawsuits against judges or courts. The opinion cited Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court.
Recusal and Case Closure
The court also addressed Bonilla’s apparent contention that Judge Hamilton’s impartiality could reasonably be questioned because of his repetitive and allegedly frivolous filings. The court rejected that contention, stating that these were not cases requiring the judge’s recusal. The opinion noted that Bonilla had named Judge Hamilton as a defendant in one of the cases but had provided no legitimate reason for recusal.
Judge Hamilton ordered that the cases be dismissed with prejudice. The clerk was directed to terminate all pending motions and close the cases, and to return without filing any additional documents Bonilla submitted in the closed cases. The opinion also noted Bonilla’s extensive history of filing similar cases, including cases assigned to four judges.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.