Bonilla v. Malicious Prosecution
- Phyllis Hamilton
- 4:24-cv-08414
- U.S. District Court · Northern District of California
- 3
In Bonilla v. U.S. District Court San Francisco, Judge Hamilton dismissed multiple civil-rights lawsuits with prejudice because filing restrictions and other legal bars applied.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. Pending motions were terminated, the cases were closed, and the clerk was directed to return future documents he submits in those closed cases without filing them.
What happened
In Steven Wayne Bonilla v. U.S. District Court San Francisco, Bonilla, a condemned state prisoner, filed multiple nearly identical civil-rights lawsuits without a lawyer against federal and state judges and other officials. He sought relief related to his conviction and the handling of his other cases.
The court ruled that Bonilla could not proceed without paying the filing fee because his allegations did not show imminent danger of serious physical injury. The court also said that, even if he could proceed without paying, the lawsuits were barred by other legal rules protecting convictions and ongoing court proceedings. The cases were dismissed with prejudice, pending motions were terminated, and the cases were closed.
Judge Phyllis J. Hamilton also rejected any suggestion that she should step aside because of the repeated filings. The clerk was instructed to return future documents Bonilla submits in these closed cases without filing them.
The detailed version
- Bonilla v. Malicious Prosecution · No. 4:24-cv-08414
- Phyllis Hamilton
- Dec. 16, 2024
Background
Bonilla, a state prisoner facing a death sentence, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints were nearly identical. They named various federal and state judges and other officials, and sought relief concerning Bonilla’s underlying conviction or the way state and federal courts handled his other cases.
The opinion states that Bonilla had a pending federal petition challenging his conviction with appointed counsel and was also represented by counsel in state-court proceedings challenging his conviction. The court referred to his prior related proceedings and his extensive history of filing similar cases.
Rulings
The court held that Bonilla was barred by 28 U.S.C. § 1915(g) from proceeding without paying the filing fee unless he showed that he was in imminent danger of serious physical injury when he filed the complaints. The allegations did not make that showing, so he could not proceed without paying the fee.
The court further ruled that, even if an application to proceed without paying the fee were granted, the lawsuits would be barred under the legal rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The court therefore dismissed the cases with prejudice.
Other Orders
The court determined that the repetitive and allegedly frivolous filings did not provide a basis to reasonably question the judge’s impartiality. Judge Hamilton did not recuse herself. The clerk was ordered to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submits in the closed cases.
Disposition
The multiple cases were dismissed with prejudice. The order applies to the numerous case numbers listed in the caption, including No. 24-cv-7972-PJH and related cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.