Bonilla v. Needham, Jr.
- Phyllis Hamilton
- 4:24-cv-09284
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Simmons, Judge Hamilton dismissed Steven Wayne Bonilla’s multiple civil-rights cases with prejudice because he showed no imminent danger and his claims were otherwise barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The ruling also affected the named federal and state judges and other officials because the cases against them were closed.
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 complaints against various federal and state judges and other officials. He sought relief concerning his conviction and the handling of his other cases.
The court held that Bonilla could not proceed without paying the filing fees because he had been barred from proceeding without fees under the federal three-strikes rule and did not show that he faced imminent danger of serious physical injury when he filed the complaints. The court also said the lawsuits would be barred for additional reasons even if an application to proceed without fees were granted.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and ordered the clerk to close the cases and return future submissions without filing them. The court also declined to find that its impartiality could reasonably be questioned because of Bonilla’s repetitive filings.
The detailed version
- Bonilla v. Needham, Jr. · No. 4:24-cv-09284
- Phyllis Hamilton
- Jan. 6, 2025
Background
Steven Wayne Bonilla, a state prisoner, filed multiple complaints representing himself under 42 U.S.C. § 1983, the federal civil-rights statute. He is described as a condemned prisoner with a pending federal petition challenging his conviction and with counsel in state-court proceedings. 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 his state and federal cases had been handled.
Court’s reasoning
The court addressed Bonilla’s ability to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated the relevant prior cases generally may not proceed without fees unless 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, so he could not proceed without fees.
The court further stated that, even if an application to proceed without 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 also stated that the repetitive and frivolous nature of the filings did not provide a basis to reasonably question the undersigned judge’s impartiality.
Disposition
Judge Phyllis J. Hamilton 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.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.