Bonilla v. Stamp
- Phyllis Hamilton
- 4:24-cv-09271
- U.S. District Court · Northern District of California
- 3
Bonilla v. Simmons: Judge Hamilton dismissed the prisoner’s multiple civil-rights cases with prejudice after finding no imminent danger and citing additional legal bars.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice and closed. The named federal and state judges and other officials were defendants in those cases.
What happened
In Steven Wayne Bonilla v. Judge Kelly V. Simmons et al., Bonilla filed multiple similar civil-rights lawsuits without a lawyer under a federal law allowing such claims against state officials. He challenged his conviction and how state and federal courts handled his other cases.
Bonilla is a condemned state prisoner with a pending federal petition challenging his detention and lawyers representing him in other proceedings. The court said he had previously been barred from filing without paying the filing fee unless he faced an immediate risk of serious physical injury, and his complaints did not show that kind of danger.
Judge Phyllis J. Hamilton dismissed all the cases with prejudice, explaining that the lawsuits would also be barred under several rules and doctrines even if Bonilla could proceed without paying. The clerk was ordered to end all pending motions, close the cases, and return future documents submitted in them without filing them.
The detailed version
- Bonilla v. Stamp · No. 4:24-cv-09271
- Phyllis Hamilton
- Jan. 6, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple pro se civil-rights complaints under 42 U.S.C. § 1983. “Pro se” means that he represented himself without a lawyer. The complaints were described as nearly identical and named various federal and state judges and other officials as defendants.
Bonilla sought relief concerning his underlying conviction and the handling of his other cases in state and federal courts. The opinion also states that he is a condemned prisoner with a pending federal petition in this district for which he has appointed counsel, and that he is represented by counsel in state-court proceedings.
Filing-fee status and legal bars
The court explained that Bonilla had been disqualified from proceeding in forma pauperis, meaning without paying the filing fee, under 28 U.S.C. § 1915(g). That statute permits a disqualified prisoner to proceed without paying only if he was in imminent danger of serious physical injury when he filed the complaint.
The court found that the allegations did not show imminent danger at the time of filing. It further stated that, even if an application to proceed without paying 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 does not separately explain how each cited doctrine applied to each case.
Ruling
Judge Phyllis J. Hamilton ordered that the cases be dismissed with prejudice. The opinion also states that the court did not find that the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. The court noted that Bonilla named the undersigned judge as a defendant in two of the cases.
The clerk was ordered to terminate all pending motions and close the cases. The clerk was also ordered to return, without filing, any further documents Bonilla submitted in the closed cases.
Disposition
The multiple cases were dismissed with prejudice, and the pending motions were terminated.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.