Bonilla v. Jackson
- Phyllis Hamilton
- 4:24-cv-08848
- U.S. District Court · Northern District of California
- 3
In Bonilla v. U.S. District Court San Francisco, Judge Hamilton dismissed the related civil-rights cases with prejudice after finding plaintiff could not proceed without paying filing fees.
Steven Wayne Bonilla’s multiple civil-rights lawsuits were dismissed with prejudice, and he may not proceed in them without paying the required filing fees.
What happened
Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits under a federal law that allows suits against certain officials. He named federal and state judges and other officials, challenging his conviction and the handling of his other cases.
The court found that Bonilla was barred from proceeding without paying filing fees because his allegations did not show an imminent danger of serious physical injury when he filed the complaints. The court also said that, even if he could proceed without paying, several legal rules would bar the lawsuits.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, directed the clerk to terminate pending motions and close the cases, and ordered that further documents submitted in the closed cases be returned without filing.
The detailed version
- Bonilla v. Jackson · No. 4:24-cv-08848
- Phyllis Hamilton
- Dec. 16, 2024
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. 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 handling of his other cases by state and federal courts.
The opinion states that Bonilla had a pending federal petition challenging his confinement in the same district, with appointed counsel, and was represented by counsel in state-court proceedings concerning that petition. The court also noted his history of filing similar cases.
Filing-fee restriction
The court held that Bonilla could not proceed without paying the filing fee under the “three strikes” provision of 28 U.S.C. § 1915(g), unless he showed 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 danger. Accordingly, Bonilla could not proceed without paying the filing fee.
Other barriers to the lawsuits
The court further stated that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under several legal doctrines and decisions: Heck v. Humphrey, which can bar civil-rights claims that would undermine a conviction or sentence; Younger v. Harris, which limits federal court intervention in certain ongoing state proceedings; and decisions concerning restrictions on suits challenging federal judicial proceedings or judgments.
The court also rejected the suggestion that the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous filings. The opinion states that the judge had a duty to decide assigned cases absent legitimate grounds for recusal.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also directed the clerk to return, without filing, any further documents Bonilla submitted in those closed cases.
The opinion lists multiple related case numbers, including 24-cv-7972-PJH, 24-cv-8268-PJH, 24-cv-8410-PJH, 24-cv-8411-PJH, 24-cv-8412-PJH, 24-cv-8413-PJH, 24-cv-8414-PJH, 24-cv-8472-PJH, 24-cv-8473-PJH, 24-cv-8501-PJH, 24-cv-8553-PJH, 24-cv-8554-PJH, 24-cv-8555-PJH, 24-cv-8632-PJH, 24-cv-8842-PJH, 24-cv-8843-PJH, 24-cv-8844-PJH, 24-cv-8845-PJH, 24-cv-8846-PJH, 24-cv-8848-PJH, 24-cv-8849-PJH, 24-cv-8850-PJH, 24-cv-8851-PJH, 24-cv-8852-PJH, 24-cv-8854-PJH, 24-cv-8855-PJH, 24-cv-8856-PJH, 24-cv-8858-PJH, 24-cv-9022-PJH, and 24-cv-9024-PJH.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.