Bonilla v. Gonzales-Rogers
- Phyllis Hamilton
- 4:24-cv-09153
- U.S. District Court · Northern District of California
- 3
Bonilla v. Simmons: Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without fees and his claims were legally barred.
Steven Wayne Bonilla’s multiple § 1983 lawsuits were dismissed with prejudice, and he could not proceed without paying filing fees because the court found no imminent danger of serious physical injury. The named judges and other officials were defendants in those cases.
What happened
In Bonilla v. Judge Kelly V. Simmons, Steven Wayne Bonilla, a condemned state prisoner proceeding without a lawyer, filed multiple nearly identical civil-rights lawsuits against judges and other officials. He challenged his conviction and how other state and federal cases were handled.
The court said Bonilla was barred from proceeding without paying filing fees unless he showed an imminent danger of serious physical injury, which his complaints did not establish. The court also said the lawsuits would be barred even if he could proceed without fees.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, closed the cases, and directed the clerk to return further filings in them without filing them.
The detailed version
- Bonilla v. Gonzales-Rogers · No. 4:24-cv-09153
- Phyllis Hamilton
- Jan. 6, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute. The complaints were nearly identical. They named various federal and state judges and other officials as defendants and sought relief concerning Bonilla’s underlying conviction and the handling of his other state and federal cases.
The opinion says Bonilla had a pending federal petition challenging his conviction in the same court, with appointed counsel, and was represented by counsel in state-court proceedings. The court also noted his extensive history of filing similar cases.
Court’s analysis
The court ruled that, to the extent Bonilla sought permission to proceed without paying filing fees, he was disqualified under 28 U.S.C. § 1915(g). That statute generally bars a prisoner with the relevant filing history from proceeding without fees 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.
The court further stated that, even if an application to proceed without fees were granted, the lawsuits would be barred under the legal doctrines identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not separately explain how each doctrine applied to each individual case.
The court also rejected any suggestion that Judge Hamilton’s impartiality could reasonably be questioned because of the repetitive and allegedly frivolous filings. The opinion notes that Bonilla named Judge Hamilton as a defendant in two of the cases.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in those closed cases.
Scope and uncertainty
The opinion lists numerous related case numbers, beginning with 24-cv-8847-PJH. The supplied case name, “Bonilla v. Gonzales-Rogers,” does not match the caption in the opinion text, which names “JUDGE KELLY V. SIMMONS et. al.” The summary therefore uses the caption shown in the opinion.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.