Bonilla
- Phyllis Hamilton
- 4:24-cv-07260
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Alameda County District Attorney’s Office, Judge Hamilton dismissed multiple prisoner civil-rights cases with prejudice because filing-fee restrictions and other legal bars applied.
Steven Wayne Bonilla, whose multiple § 1983 cases were dismissed with prejudice, and the defendants named in those cases.
What happened
Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights lawsuits under a federal law allowing claims against government actors. He named various federal and state judges and state courts as defendants and challenged his conviction or the handling of his other cases.
The court said Bonilla could not proceed without paying filing fees because he had been disqualified under federal law and had not shown an imminent danger of serious physical injury when he filed. The court also said the lawsuits would be barred by several other legal doctrines, even if his applications to waive the fees were granted.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and closed the cases. The clerk was instructed to return without filing any further documents Bonilla submitted in those closed cases.
The detailed version
- Bonilla · No. 4:24-cv-07260
- Phyllis Hamilton
- Oct. 24, 2024
Background
Steven Wayne Bonilla, a state prisoner, filed multiple pro se civil-rights complaints under 42 U.S.C. § 1983. The opinion identifies the matters by numerous case numbers, including 24-cv-6883-PJH, 24-cv-6885-PJH, 24-cv-6924-PJH, 24-cv-6925-PJH, and others. The complaints asserted nearly identical claims against various federal and state judges and state courts. Bonilla sought relief concerning his underlying conviction or the way his other state and federal cases had been handled.
The opinion also notes that Bonilla is a condemned prisoner with a pending federal petition challenging his custody, for which he has appointed counsel, and that he is represented by counsel in state-court proceedings. Those proceedings were referenced as background to the new complaints.
Filing-fee restriction and other bars
The court addressed Bonilla’s possible requests to proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated the relevant prior dismissals generally cannot proceed without paying the fees unless the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court stated that Bonilla had already been disqualified from proceeding without paying the fees and that these complaints did not show such imminent danger.
The court further stated that, even if an application to proceed without paying the fees were granted, the lawsuits would be barred under the 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 decide the underlying allegations on their merits.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases.
The court also rejected any suggestion that the judge’s impartiality could reasonably be questioned because of the repetitive and allegedly frivolous filings. The opinion states that Bonilla named the judge as a defendant in three of the cases but made no specific allegations against her. Judge Phyllis J. Hamilton signed the order.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.