Bonilla v. Mayfield
- Phyllis Hamilton
- 4:24-cv-09281
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Simmons, Judge Hamilton dismissed the prisoner’s multiple civil-rights cases with prejudice because he showed no imminent danger and his claims were barred.
Steven Wayne Bonilla and the defendants named in his multiple federal civil-rights cases were affected; the cases were closed with prejudice.
What happened
In Steven Wayne Bonilla v. Judge Kelly V. Simmons et al., Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits against federal and state judges and other officials. He challenged 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 not shown that he faced imminent danger of serious physical injury when he filed the complaints. The court also said that, even if he could proceed without paying, the lawsuits would be barred by several legal doctrines and dismissed the cases with prejudice. The clerk was ordered to terminate pending motions, close the cases, and return further filings in them without filing them.
Judge Phyllis J. Hamilton also ruled that the repetitive and frivolous filings did not provide a basis to question her impartiality. The order was entered on January 6, 2025.
The detailed version
- Bonilla v. Mayfield · No. 4:24-cv-09281
- Phyllis Hamilton
- Jan. 6, 2025
Background
Steven Wayne Bonilla, described as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983, a federal law that permits certain claims against state officials. The complaints presented nearly identical claims and named various federal and state judges and other officials as defendants. Bonilla sought relief concerning his underlying conviction and the way his other state and federal court cases had been handled.
The order states that Bonilla had a pending federal petition challenging his conviction in the same court with appointed counsel and was also represented by counsel in state court proceedings concerning that conviction. The opinion also notes that he had an extensive history of filing similar cases.
Filing-fee determination
The court addressed Bonilla’s possible requests to proceed without prepaying filing fees, a status commonly called proceeding in forma pauperis. Under 28 U.S.C. § 1915(g), the court said Bonilla was disqualified from that status unless he showed that he faced imminent danger of serious physical injury when he filed each complaint. The court found that the allegations did not show imminent danger at the relevant time.
Other grounds for dismissal
The court further stated that, even if an application to proceed without prepaying fees were granted, the lawsuits would be barred under the doctrines or rules 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 cited authority applied to each individual case.
Ruling
The court dismissed the cases with prejudice. 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.
The court additionally considered whether the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous filings. It concluded that these were not cases requiring the undersigned judge’s recusal. The order was signed by Phyllis J. Hamilton, United States District Judge.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.