Bonilla v. Bamattre-Manoukian
- Phyllis Hamilton
- 4:24-cv-09460
- U.S. District Court · Northern District of California
- 3
In Steven Wayne Bonilla v. Judge Kelly V. Simmons, Judge Hamilton dismissed multiple pro se civil-rights cases with prejudice because Bonilla was barred from proceeding without fees.
Steven Wayne Bonilla’s multiple § 1983 cases were dismissed with prejudice; pending motions were terminated, the cases were closed, and future documents submitted in them were to be returned without filing.
What happened
Steven Wayne Bonilla, a condemned state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits against federal and state judges and other officials. He sought relief concerning his conviction and how other state and federal court cases were handled.
The court found that Bonilla did not show he faced an immediate risk of serious physical injury when he filed the complaints. Because he had previously been disqualified from proceeding without paying filing fees, he could not proceed without fees. The court also stated that the lawsuits would be barred by several legal doctrines even if his applications to proceed without fees were granted.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and directed the clerk to close the cases and return without filing any further documents Bonilla submitted in them.
The detailed version
- Bonilla v. Bamattre-Manoukian · No. 4:24-cv-09460
- Phyllis Hamilton
- Jan. 6, 2025
Background
Steven Wayne Bonilla filed multiple nearly identical civil-rights complaints under 42 U.S.C. § 1983 while representing himself. The opinion identifies him as a state prisoner who has been condemned. The defendants include various federal and state judges and other officials. The complaints seek relief concerning Bonilla’s underlying conviction or the handling of his other cases in state and federal court.
The order addresses multiple related cases, including case numbers 24-cv-8847-PJH, 24-cv-8857-PJH, 24-cv-9025-PJH, 24-cv-9026-PJH, 24-cv-9152-PJH, 24-cv-9153-PJH, 24-cv-9175-PJH, 24-cv-9256-PJH, 24-cv-9257-PJH, 24-cv-9258-PJH, 24-cv-9259-PJH, 24-cv-9260-PJH, 24-cv-9261-PJH, 24-cv-9262-PJH, 24-cv-9263-PJH, 24-cv-9264-PJH, 24-cv-9266-PJH, 24-cv-9267-PJH, 24-cv-9269-PJH, 24-cv-9270-PJH, 24-cv-9271-PJH, 24-cv-9272-PJH, 24-cv-9281-PJH, 24-cv-9282-PJH, 24-cv-9284-PJH, 24-cv-9458-PJH, 24-cv-9459-PJH, 24-cv-9460-PJH, 24-cv-9461-PJH, 24-cv-9491-PJH, 24-cv-9492-PJH, 24-cv-9495-PJH, 24-cv-9496-PJH, 24-cv-9497-PJH, 24-cv-9498-PJH.
Reasoning
The court explained that Bonilla had been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g), unless he showed that he was in immediate danger of serious physical injury when he filed the complaint. The court found that the allegations did not show such danger. Therefore, Bonilla could not proceed without paying the required fees.
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the legal doctrines identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion does not separately analyze which doctrine applies to which complaint.
The court also rejected any suggestion that the judge’s impartiality could reasonably be questioned because of Bonilla’s repetitive and frivolous filings. The opinion notes that Bonilla named the judge as a defendant in two of the cases.
Disposition
Judge Phyllis J. Hamilton dismissed the cases with prejudice. The clerk was directed to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any further documents Bonilla submitted in the closed cases. The opinion states that Bonilla has an extensive history of filing similar cases, but it does not identify a separate disposition for any particular claim or defendant.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.