Bonilla v. Hamilton
- Phyllis Hamilton
- 4:24-cv-09152
- U.S. District Court · Northern District of California
- 3
In Steven Wayne Bonilla v. Judge Kelly V. Simmons, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without fees and his claims were barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The order also directed the clerk to terminate pending motions, close the cases, and return later submissions without filing them.
What happened
In Steven Wayne Bonilla v. Judge Kelly V. Simmons, Steven Wayne Bonilla, a condemned state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits against federal and state judges and other officials. The lawsuits concerned his conviction and how other court cases were handled.
The court ruled that Bonilla could not proceed without paying filing fees because his allegations did not show imminent danger of serious physical injury when he filed the complaints. The court also said that, even if he could proceed without those fees, legal barriers still applied to the lawsuits. It dismissed the cases with prejudice.
Judge Phyllis J. Hamilton also ordered the clerk to terminate all pending motions, close the cases, and return without filing any further documents Bonilla submits in them. The court rejected the argument that the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous filings.
The detailed version
- Bonilla v. Hamilton · No. 4:24-cv-09152
- Phyllis Hamilton
- Jan. 6, 2025
Background
Steven Wayne Bonilla, a state prisoner, filed multiple complaints under 42 U.S.C. § 1983, a federal law allowing certain civil-rights claims against state officials. He represented himself in these cases. The complaints were nearly identical and named various federal and state judges and other officials as defendants. They sought relief concerning Bonilla’s underlying conviction and the handling of his other state and federal cases.
The opinion states that Bonilla had a pending federal petition challenging his imprisonment in the same court, where he had appointed counsel. It also states that he was represented by counsel in state proceedings seeking similar relief.
Reasons for dismissal
The court held that Bonilla could not proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated the relevant prior dismissals generally cannot proceed without those fees unless he was in imminent danger of serious physical injury when he filed the complaint. The court found that Bonilla’s allegations did not show such imminent danger at the time of filing.
The court further stated that, even if an application to proceed without paying filing fees were granted, the lawsuits would still be barred under the legal doctrines identified in the opinion, including rules concerning challenges to criminal convictions, interference with ongoing state proceedings, and suits against federal judges or courts. The opinion did not decide the underlying claims in Bonilla’s favor or the defendants’ favor.
Disposition
Judge Phyllis J. Hamilton ordered that the cases be dismissed with prejudice. The clerk was directed to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any further documents Bonilla submits in these closed cases.
Bonilla named Judge Hamilton as a defendant in two of the cases. The court nevertheless concluded that these were not cases in which the judge’s impartiality might reasonably be questioned because of the repetitive and frivolous nature of the filings. The opinion also notes Bonilla’s extensive history of filing similar cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.