Bonilla v. Simmons
- Phyllis Hamilton
- 4:24-cv-07261
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Alameda County District Attorney’s Office, Judge Hamilton dismissed multiple cases with prejudice because Bonilla could not proceed without paying and his claims were barred.
Steven Wayne Bonilla and the multiple cases covered by the order; all pending motions were terminated, the cases were closed, and future documents submitted in those closed cases were to be returned without filing.
What happened
In Steven Wayne Bonilla v. Alameda County District Attorney’s Office et al., Bonilla, a condemned state prisoner representing himself, filed multiple nearly identical civil-rights cases. He sued various federal and state judges and state courts over his conviction and how his other cases were handled.
The court said Bonilla was barred from proceeding without paying filing fees because his complaints did not show that he faced an immediate serious physical danger when he filed them. The court also said that, even if he had been allowed to proceed without paying, the lawsuits would be barred by several legal rules protecting convictions and ongoing court proceedings.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and ordered the clerk to close the cases. The clerk was also directed to return without filing any further documents Bonilla submitted in these closed cases.
The detailed version
- Bonilla v. Simmons · No. 4:24-cv-07261
- Phyllis Hamilton
- Oct. 24, 2024
Background
Steven Wayne Bonilla, a condemned state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute for claims against government actors. The order covers the multiple case numbers listed in the caption. Bonilla named various federal and state judges and state courts as defendants. His complaints presented nearly identical claims concerning his underlying conviction and the way his other state and federal cases had been handled.
The order notes that Bonilla has a pending federal petition challenging his detention, in which he has appointed counsel, and that he is represented by counsel in state court proceedings challenging his detention.
Filing-fee status and dismissal grounds
Bonilla sought, or could have sought, permission to proceed without paying filing fees. The court held that he was disqualified from doing so under 28 U.S.C. § 1915(g), which prevents a prisoner with the relevant filing history from proceeding without paying unless the complaint shows that the prisoner faced an immediate danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show such danger.
The court further stated that, even if Bonilla had been allowed to proceed without paying, his lawsuits would be barred under the rules identified in the order: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order also referred to Bonilla’s extensive history of filing similar cases.
Ruling
Judge Phyllis J. Hamilton ordered that the cases be dismissed with prejudice. The court directed the clerk to terminate all pending motions and close the cases. It also directed the clerk to return, without filing, any further documents Bonilla submitted in these closed cases.
The order separately addressed Bonilla’s naming of Judge Hamilton as a defendant in three of the cases. It concluded that the repetitive and allegedly frivolous filings did not provide a legitimate reason to question the judge’s impartiality or require her recusal.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.