Bonilla v. Casse
- Phyllis Hamilton
- 4:24-cv-09259
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Simmons, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla showed no imminent danger and several legal bars applied.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice. The order also ended pending motions and closed the cases.
What happened
In Steven Wayne Bonilla v. Judge Kelly V. Simmons et al., Bonilla, a state prisoner proceeding without a lawyer, filed multiple nearly identical civil-rights cases against various federal and state judges and other officials. The cases sought relief concerning his conviction and the handling of his other state and federal court cases.
The court found that Bonilla had been disqualified from filing without paying fees under a federal law because he had filed three or more cases dismissed as frivolous, unless he faced imminent danger of serious physical injury. The complaints did not show such danger. The court also stated that, even if Bonilla could proceed without paying fees, the lawsuits were barred by several legal doctrines and decisions.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, closed the cases, and directed the clerk to return without filing any further documents Bonilla submitted in them.
The detailed version
- Bonilla v. Casse · No. 4:24-cv-09259
- 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, a federal civil-rights statute. The opinion lists numerous case numbers, beginning with 24-cv-8847-PJH and including many other cases. Bonilla named various federal and state judges and other officials as defendants. The complaints presented nearly identical claims and sought relief concerning his underlying conviction or the handling of his other state and federal court cases.
The court noted that Bonilla had a pending federal petition challenging his custody in the same court, with appointed counsel, and was represented by counsel in state court proceedings. Those related proceedings were cited in the opinion by their case numbers.
Filing-fee restriction
To the extent Bonilla sought permission to proceed without paying the filing fee, the court found that 28 U.S.C. § 1915(g) disqualified him from doing so unless he was in imminent danger of serious physical injury when he filed the complaints. The court referred to prior proceedings in finding that Bonilla had been disqualified under that provision. It determined that the allegations did not show imminent danger at the time of filing.
Other grounds for dismissal
The court further stated that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion did not decide the underlying conviction-related or case-handling claims on their merits.
Ruling
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 the closed cases. The court also rejected the suggestion that the judge's impartiality could reasonably be questioned merely because of the repetitive and frivolous nature of the filings. Judge Phyllis J. Hamilton signed the order on January 6, 2025.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.