Bonilla v. Lloyd
- Phyllis Hamilton
- 4:24-cv-05992
- U.S. District Court · Northern District of California
- 2
In Steven Wayne Bonilla v. Judge Beth L. Freeman, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent-danger exception and other legal barriers.
Steven Wayne Bonilla’s multiple civil-rights lawsuits were dismissed with prejudice; the named federal and state judge defendants were affected by the closure of those cases.
What happened
Steven Wayne Bonilla v. Judge Beth L. Freeman involved multiple nearly identical complaints filed without a lawyer under a federal civil-rights law. Bonilla, a state prisoner, sued various federal and state judges and sought relief concerning his conviction or the handling of other cases.
The court found that Bonilla could not proceed without paying the filing fee because his allegations did not show that he faced imminent danger of serious physical injury when he filed the complaints. The court also said that, even if he had been allowed to proceed without paying, legal rules would bar the lawsuits.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and closed the cases. The clerk was directed to return without filing any further documents Bonilla submitted in those closed cases.
The detailed version
- Bonilla v. Lloyd · No. 4:24-cv-05992
- Phyllis Hamilton
- Sept. 26, 2024
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The complaints were nearly identical and named various federal and state judges as defendants. They sought relief related to Bonilla’s underlying conviction or the handling of his other state and federal cases. The opinion also states that Bonilla had a pending federal petition challenging his custody with appointed counsel and was represented by counsel in state-court proceedings.
Filing-Fee Ruling
The court explained that Bonilla had previously been barred from proceeding without paying the filing fee under the three-strikes provision of 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. It therefore ruled that Bonilla could not proceed without paying the filing fee.
Other Grounds for Dismissal
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 legal principles discussed in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion did not decide the underlying conviction-related or case-handling claims on their merits. It also stated that the repetitive and allegedly frivolous filings did not provide a reasonable basis to question the undersigned judge’s impartiality.
Disposition
Judge Phyllis J. Hamilton dismissed the cases with prejudice. The clerk was ordered 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 court disposed of the matters based on filing-fee eligibility and other threshold legal grounds rather than deciding the underlying claims, this is a procedural order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.