Bonilla v. Illman
- Phyllis Hamilton
- 4:24-cv-06925
- U.S. District Court · Northern District of California
- 3
Bonilla v. Alameda County District Attorney’s Office: Judge Hamilton dismissed multiple prisoner civil-rights cases with prejudice under filing and claim bars.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice, and future documents submitted in those closed cases were ordered returned without filing.
What happened
In Bonilla v. Alameda County District Attorney’s Office et al., Steven Wayne Bonilla, a state prisoner without a lawyer, filed multiple nearly identical civil-rights cases. He sued various federal and state judges and courts over his conviction and how his other cases were handled.
The court found that Bonilla could not avoid the filing-fee rule because his complaints did not show that he faced an immediate danger of serious physical injury when he filed them. The court also said that, even if he were allowed to proceed without paying the filing fee, several legal rules would bar the lawsuits.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and ordered the clerk to close the cases and return future documents submitted in them without filing them.
The detailed version
- Bonilla v. Illman · No. 4:24-cv-06925
- Phyllis Hamilton
- Oct. 24, 2024
Background
Steven Wayne Bonilla, described as a state prisoner and a condemned prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a statute that allows certain civil-rights claims against state actors. The complaints presented nearly identical claims and named various federal and state judges and state courts as defendants. Bonilla sought relief concerning his underlying conviction and the handling of his other state and federal cases. The opinion also states that he had a pending federal petition challenging his detention with appointed counsel and was represented by counsel in state proceedings.
Filing-fee restriction
The court stated that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That rule allows a disqualified prisoner to proceed without the fee only if the complaint shows that the prisoner was in immediate danger of serious physical injury when the complaint was filed. The court found that these complaints did not show such danger. Bonilla therefore could not proceed without paying the filing fee.
Other barriers to the lawsuits
The court further ruled that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred by several legal doctrines and precedents, including rules concerning challenges to criminal convictions, interference with ongoing proceedings, and lawsuits against federal judges or courts. The court did not decide whether Bonilla’s underlying allegations were legally correct. It also rejected any concern that the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. The opinion noted that Bonilla named the judge as a defendant in three cases but made no specific allegations against her.
Disposition
The court dismissed the cases with prejudice. The clerk was ordered to terminate all pending motions and close the cases. The clerk was also ordered to return, without filing, any further documents Bonilla submitted in the closed cases. The order was signed by United States District Judge Phyllis J. Hamilton on October 24, 2024.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.