Bonilla v. Casse
- Phyllis Hamilton
- 4:24-cv-08843
- 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 after finding no imminent danger and legal barriers.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice. The named federal and state judges and other officials were defendants in those cases, and the cases were closed with pending motions terminated.
What happened
In Steven Wayne Bonilla v. U.S. District Court San Francisco et al., the plaintiff, a state prisoner, filed multiple nearly identical civil-rights lawsuits without a lawyer. He named federal and state judges and other officials and sought relief concerning his conviction and the handling of his other cases.
The court held that Bonilla could not proceed without paying the filing fee because he did not show that he faced an imminent danger of serious physical injury when he filed the complaints. The court also said that, even if he could proceed without paying, the lawsuits would be barred by several legal doctrines and cases, including rules concerning challenges to convictions and interference with ongoing proceedings.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and ordered the clerk to close the cases. The clerk was also ordered to return without filing any further documents Bonilla submitted in the closed cases.
The detailed version
- Bonilla v. Casse · No. 4:24-cv-08843
- Phyllis Hamilton
- Dec. 16, 2024
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints presented nearly identical claims and named various federal and state judges and other officials as defendants. Bonilla sought relief concerning his underlying conviction and the handling of his other cases by state and federal courts.
The opinion states that Bonilla had a pending federal petition challenging his custody in the same court, with appointed counsel, and was represented by counsel in state-court proceedings. The opinion also states that he had an extensive history of filing similar cases.
Proceeding Without Paying the Filing Fee
The court addressed Bonilla's possible requests to proceed in forma pauperis, meaning without prepaying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner disqualified under that provision may proceed without prepaying only if he shows that he was in imminent danger of serious physical injury when he filed the complaint. The court found that the allegations did not show such imminent danger. Accordingly, Bonilla could not proceed in forma pauperis in these cases.
Other Legal Bars
The court further stated that, even if an application to proceed in forma pauperis 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 opinion does not provide a separate claim-by-claim analysis explaining which cited bar applied to which complaint.
Ruling
The court dismissed the cases with prejudice. It also stated that the repetitive and frivolous nature of the filings did not provide a basis to reasonably question the undersigned judge's impartiality, even though Bonilla named that judge as a defendant in one of the cases.
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.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.