Bonilla v. Lloyd
- Phyllis Hamilton
- 4:24-cv-06334
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Judge Freeman, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without filing fees and the lawsuits were barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice and closed. The complaints named various federal and state judges as defendants.
What happened
In Steven Wayne Bonilla v. Judge Beth L. Freeman et al., Bonilla, a state prisoner, filed multiple nearly identical civil-rights lawsuits against various federal and state judges. He challenged his conviction and the handling of his other cases.
Bonilla sought to proceed without paying filing fees, but the court said he was barred from doing so unless he showed that he faced imminent danger of serious physical injury when he filed. The court found that his complaints did not make that showing.
Judge Phyllis J. Hamilton also ruled that the lawsuits would be barred even if Bonilla were allowed to proceed without paying fees. She dismissed the cases with prejudice, terminated the pending motions, and ordered the clerk to close the cases.
The detailed version
- Bonilla v. Lloyd · No. 4:24-cv-06334
- Phyllis Hamilton
- Sept. 26, 2024
Background
Steven Wayne Bonilla, identified by the court as a state prisoner and a condemned prisoner, filed multiple self-represented civil-rights complaints under 42 U.S.C. § 1983. The complaints were nearly identical and named various federal and state judges as defendants. Bonilla sought relief concerning his underlying conviction and the handling of other cases in state and federal court.
The court noted that Bonilla had a pending federal petition challenging his custody with appointed counsel and was also represented by counsel in state-court proceedings concerning that petition. The opinion also noted that he had an extensive history of filing similar cases.
Filing-fee status
The court said 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 imminent danger at the relevant time. It therefore ruled that Bonilla could not proceed without paying the filing fee.
Other grounds for dismissal
The court further ruled that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under the legal doctrines identified in 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 explaining which doctrine applied to which complaint.
The court also addressed impartiality and stated that the repetitive and frivolous nature of the filings did not provide a reasonable basis to question the undersigned judge’s impartiality. It cited the principle that, absent legitimate reasons for recusal, a judge has a duty to decide assigned cases.
Disposition
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.