Bonilla v. Villarreal
- Phyllis Hamilton
- 4:24-cv-08553
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Villarreal, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without fees and the lawsuits were barred.
Steven Wayne Bonilla and the defendants in the multiple listed cases. The cases were closed, pending motions were terminated, and future documents submitted in those cases were ordered returned without filing.
What happened
In Bonilla v. Villarreal, Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple nearly identical civil-rights lawsuits against federal and state judges and other officials. He sought relief concerning his conviction and the handling of his other cases.
The court ruled that Bonilla was disqualified from filing without paying fees because his complaints did not show that he faced imminent danger of serious physical injury when he filed them. The court also said that, even if he had qualified for fee-free filing, the lawsuits would be barred under several cited legal rules.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, directed the clerk to terminate all pending motions and close the cases, and ordered that future documents Bonilla submits in them be returned without filing.
The detailed version
- Bonilla v. Villarreal · No. 4:24-cv-08553
- Phyllis Hamilton
- Dec. 16, 2024
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute used for certain claims against government officials. 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 his other cases had been handled.
The order also states that Bonilla had a pending federal petition challenging his conviction in the same court, with appointed counsel, and was represented by counsel in state-court proceedings concerning his conviction.
Fee-free filing status
The court stated that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying the required filing fees unless he showed that he was in imminent danger of serious physical injury when he filed his complaints. The court found that the allegations did not show such danger. It therefore ruled that Bonilla could not proceed without paying the fees.
Other barriers identified by the court
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The order did not assign each cited rule to particular claims.
Ruling and case disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also ordered the clerk to return, without filing, any further documents Bonilla submits in the closed cases.
The court additionally rejected the suggestion that the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. The opinion states that the undersigned judge was the fourth judge assigned cases filed by Bonilla and that Bonilla named the judge as a defendant in one of the cases.
Classification
This is a procedural order because the court disposed of the cases based on fee-status and other threshold barriers rather than deciding the underlying civil-rights claims on their merits.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.