Bonilla v. Illman
- Phyllis Hamilton
- 4:24-cv-08854
- 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 could not proceed without paying and the suits were barred.
Steven Wayne Bonilla’s multiple federal civil-rights cases were dismissed with prejudice. The various federal and state judges and other officials named as defendants were affected by the closure of those cases.
What happened
Bonilla v. U.S. District Court San Francisco involved multiple nearly identical complaints filed by state prisoner Steven Wayne Bonilla without a lawyer under federal civil-rights law. He sued various federal and state judges and officials and sought relief concerning his conviction and the handling of his other cases.
The court said Bonilla was barred from proceeding without paying the filing fees unless he showed that he faced an immediate risk of serious physical injury when he filed. The complaints did not show that risk. The court also said that, even if he were allowed to proceed without paying, the lawsuits were barred by several legal rules concerning challenges to convictions, ongoing proceedings, and court decisions.
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 submitted in those closed cases be returned without filing.
The detailed version
- Bonilla v. Illman · No. 4:24-cv-08854
- Phyllis Hamilton
- Dec. 16, 2024
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The order covers the cases listed in the caption, including No. 24-cv-7972-PJH and numerous related case numbers. The complaints were nearly identical. Bonilla named various federal and state judges and other officials as defendants and sought relief concerning his underlying conviction and the handling of his other cases.
The order states that Bonilla had a pending federal petition challenging his conviction in this court with appointed counsel. It also states that he was represented by counsel in state proceedings challenging his imprisonment.
Proceeding Without Filing Fees
The court addressed Bonilla’s request, or possible request, to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from proceeding without fees may do so only if the complaint shows that the prisoner faced an immediate danger of serious physical injury when the complaint was filed. The court said Bonilla had been disqualified under that statute and that his allegations did not show the required danger. Therefore, he could not proceed without paying the filing fees.
Other Bars Identified by the Court
The court further held that, even if Bonilla’s request to proceed without paying fees 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 opinion described the cases as challenging Bonilla’s conviction or the way state and federal courts handled his other cases. The court did not reach the underlying merits of those claims.
Disqualification and Case Closure
The court rejected Bonilla’s suggestion that the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous filings. The order noted that Bonilla named Judge Hamilton as a defendant in one of the cases, but the excerpt does not provide further details about that case.
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases, and directed the clerk to return without filing any further documents Bonilla submitted in those closed cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.