Bonilla v. Jackson
- Phyllis Hamilton
- 4:24-cv-09263
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Simmons, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying filing fees and his lawsuits were barred.
Steven Wayne Bonilla’s multiple civil-rights cases and the defendants named in them; the clerk was directed to close the cases and return later submissions without filing them.
What happened
In Steven Wayne Bonilla v. Judge Kelly V. Simmons et. al., Bonilla, a condemned state prisoner representing himself, filed multiple nearly identical civil-rights cases against federal and state judges and other officials. He sought relief related to his conviction and the handling of his other court cases.
The court said Bonilla was barred from proceeding without paying filing fees because he did not show that he faced an immediate danger of serious physical injury when he filed the complaints. The court also said that, even if he could proceed without paying, the lawsuits were barred under several legal rules and prior decisions.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ordered the clerk to terminate all pending motions and close the cases, and directed the clerk to return any further documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Jackson · No. 4:24-cv-09263
- Phyllis Hamilton
- Jan. 6, 2025
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 while representing himself. The complaints presented nearly identical claims against various federal and state judges and other officials. Bonilla sought relief concerning his underlying conviction or the way state and federal courts handled his other cases.
The opinion states that Bonilla was a condemned prisoner with a pending federal petition challenging his custody in the same court, where he had appointed counsel. It also states that he was represented by counsel in state-court proceedings concerning that petition.
Reasons for Dismissal
The court addressed Bonilla’s ability to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified under the statute may proceed without paying only if the complaint shows that the prisoner faced 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 filing fees.
The court further stated that, even if an application to proceed without paying fees 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 also noted Bonilla’s extensive history of filing similar cases.
The court rejected the suggestion that the assigned judge’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. The opinion states that, absent legitimate grounds for disqualification, a judge has a duty to decide cases assigned to that judge.
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 the closed cases. The order was signed by United States District Judge Phyllis J. Hamilton on January 6, 2025.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.