Bonilla v. Cantil-Sakuye
- Phyllis Hamilton
- 4:24-cv-08851
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Cantil-Sakuye, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla did not qualify for fee-free filing and his claims were barred.
Steven Wayne Bonilla and the defendants in the multiple cases, which the opinion describes as various federal and state judges and other officials.
What happened
In Bonilla v. Cantil-Sakuye, Steven Wayne Bonilla, a state prisoner under a death sentence, filed multiple nearly identical civil-rights lawsuits without a lawyer. He sued various federal and state judges and other officials over his conviction and the handling of his other cases.
The court said Bonilla could not proceed without paying filing fees because he had previously been disqualified from fee-free filing, and his complaints did not show that he faced an immediate risk of serious physical injury when he filed them. The court also said that, even if fee-free filing were allowed, the lawsuits were barred by several legal doctrines and prior decisions.
Judge Phyllis Hamilton dismissed the cases with prejudice, ended all pending motions, and closed the cases. The clerk was directed to return any additional documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Cantil-Sakuye · No. 4:24-cv-08851
- Phyllis Hamilton
- Dec. 16, 2024
Background
Steven Wayne Bonilla, described as a state prisoner and a condemned prisoner, filed multiple complaints under 42 U.S.C. § 1983, a federal civil-rights statute. He filed the complaints without a lawyer. The cases presented nearly identical claims against various federal and state judges and other officials. Bonilla sought relief concerning his underlying conviction and the handling of his other state and federal cases.
The opinion notes that Bonilla had a pending federal petition challenging his imprisonment in the same court with appointed counsel, and that he was represented by counsel in state-court proceedings concerning his imprisonment.
Filing-fee restriction and claim barriers
The court held that Bonilla was disqualified from proceeding in the cases without paying the filing fees under 28 U.S.C. § 1915(g), unless he showed that he was in immediate danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger.
The court further stated that, even if an application to proceed without paying the filing fees were granted, the lawsuits would be barred under the legal rules and decisions identified as Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court.
Ruling
The court dismissed the cases with prejudice. It also rejected the suggestion that the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. The clerk was directed to terminate all pending motions, close the cases, and return without filing any further documents Bonilla submitted in those closed cases.
The order was signed by United States District Judge Phyllis J. Hamilton on December 16, 2024.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.