Bonilla v. Bamattre
- Phyllis Hamilton
- 4:24-cv-08472
- U.S. District Court · Northern District of California
- 3
In Bonilla v. U.S. District Court San Francisco, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla did not show imminent danger and the claims were barred.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice. The clerk was ordered to close the cases, terminate pending motions, and return later submissions without filing them; the named defendants were not required to litigate these complaints further.
What happened
In Steven Wayne Bonilla v. U.S. District Court San Francisco et al., Bonilla, a state prisoner, filed multiple nearly identical self-represented civil-rights complaints under federal law. He sued various federal and state judges and other officials over his conviction and the handling of his other cases.
The court found that Bonilla could not proceed without paying the filing fees because he did not show that he faced an immediate risk of serious physical injury when he filed the complaints. The court also stated that, even if he had been allowed to proceed without paying fees, the lawsuits would be barred by several legal rules and prior decisions.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ordered the clerk to terminate pending motions and close the cases, and directed the clerk to return future documents submitted in those closed cases without filing them. The court also rejected the argument that the judge's impartiality could reasonably be questioned.
The detailed version
- Bonilla v. Bamattre · No. 4:24-cv-08472
- Phyllis Hamilton
- Dec. 16, 2024
Background
Steven Wayne Bonilla, a state prisoner, filed multiple self-represented civil-rights complaints under 42 U.S.C. § 1983. The complaints were nearly identical. Bonilla named various federal and state judges and other officials as defendants, and sought relief concerning his underlying conviction or the handling of his other cases by state and federal courts.
The opinion states that Bonilla is a condemned prisoner with a pending federal petition challenging his custody in the same court, where he has appointed counsel. It also states that he is represented by counsel in state-court proceedings concerning his custody.
Court's reasoning
The court held that Bonilla was disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g), unless he showed that he was in imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such imminent danger.
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the rules or doctrines identified in the opinion: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court.
The court also addressed judicial impartiality. Although Bonilla named the judge as a defendant in one case, the court concluded that the repetitive and allegedly frivolous nature of the filings did not create a reasonable question about the judge's impartiality. The opinion states that, absent legitimate grounds for recusal, a judge has a duty to decide cases assigned to that judge.
Disposition
Judge Phyllis J. Hamilton dismissed the cases with prejudice. The clerk was ordered 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.
The opinion notes that the undersigned judge was the fourth judge assigned to cases filed by Bonilla and that this was the 70th such case.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.