Bonilla v. Cantil-Sakauye
- Phyllis Hamilton
- 4:24-cv-09258
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Simmons, Judge Hamilton dismissed the cases with prejudice after denying fee-free filing and identifying legal barriers to the lawsuits.
Steven Wayne Bonilla’s multiple civil-rights cases against Judge Kelly V. Simmons and other federal and state judges and officials were dismissed with prejudice. The order also terminated pending motions, closed the cases, and directed the clerk not to file further documents submitted in them.
What happened
In Steven Wayne Bonilla v. Judge Kelly V. Simmons et al., Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits against judges and other officials. The lawsuits sought relief related to his conviction and the handling of his other state and federal court cases.
The court ruled that Bonilla could not proceed without paying the filing fees because he had been barred from fee-free filing under federal law and had not shown an immediate danger of serious physical injury when he filed. The court also said that, even if he could proceed without paying, the lawsuits would be barred by several legal doctrines. It dismissed the cases with prejudice, ended all pending motions, and directed the clerk to close the cases.
Judge Phyllis J. Hamilton issued the order on January 6, 2025. The court also rejected the suggestion that the judge’s impartiality could reasonably be questioned because of Bonilla’s repetitive filings and directed the clerk to return future documents submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Cantil-Sakauye · No. 4:24-cv-09258
- Phyllis Hamilton
- Jan. 6, 2025
Background
Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The order covers the cases listed under numerous case numbers, including 24-cv-8847-PJH and 24-cv-8857-PJH. Bonilla is a condemned prisoner with a pending federal petition challenging his conviction in the same court, where he has appointed counsel. The order also states that he is represented by counsel in state-court proceedings.
The complaints presented nearly identical claims against various federal and state judges and other officials. The requested relief concerned Bonilla’s underlying conviction or the way his other cases had been handled by state and federal courts.
Court’s analysis
The court addressed Bonilla’s requests to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated the relevant prior dismissals generally may not proceed without paying unless the complaint shows that the prisoner faced an imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show such danger. It therefore ruled that he could not proceed without paying the filing fees.
The court added that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the legal doctrines identified in the order: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order did not provide a separate claim-by-claim analysis of those doctrines.
The court also considered whether the judge’s impartiality could reasonably be questioned because Bonilla had filed repetitive and frivolous cases, including two cases naming the judge as a defendant. The court concluded that these circumstances did not require the judge to step aside.
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 submits in the closed cases.
The order states that the judge was the fourth judge assigned to Bonilla’s cases and that Bonilla had filed many other cases. Those statements appear in footnotes to the order and were not necessary to the stated dismissal grounds.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.