Bonilla v. White
- Phyllis Hamilton
- 4:24-cv-09498
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Simmons, Judge Hamilton dismissed the related civil-rights cases with prejudice after finding no imminent danger and identifying multiple legal bars.
The order affected Steven Wayne Bonilla's multiple related civil-rights cases. The cases were dismissed with prejudice, pending motions were terminated, and the cases were closed.
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 under a federal civil-rights law. He sued various federal and state judges and other officials over his conviction and how his other cases were handled.
The court ruled that Bonilla could not proceed without paying the filing fees because his allegations did not show imminent danger of serious physical injury when he filed. The court also said that, even if he could proceed without those fees, the lawsuits would be barred by several legal doctrines and decisions. It dismissed the cases with prejudice, terminated pending motions, and closed the cases.
Judge Phyllis J. Hamilton also rejected any suggestion that her impartiality could reasonably be questioned because of Bonilla's repetitive filings. The clerk was ordered to return future documents submitted in the closed cases without filing them.
The detailed version
- Bonilla v. White · No. 4:24-cv-09498
- Phyllis Hamilton
- Jan. 6, 2025
Background
Steven Wayne Bonilla, a state prisoner facing a death sentence, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a federal law allowing certain civil-rights claims against state actors. The opinion lists numerous related case numbers. The complaints presented nearly identical claims against various federal and state judges and other officials. Bonilla sought relief concerning his underlying conviction and the handling of his other state and federal cases.
The opinion states that Bonilla had a pending federal petition challenging his detention or conviction in the same court with appointed counsel, and that he was represented by counsel in state court proceedings. The court also noted his history of filing similar cases.
Court’s analysis
The court addressed Bonilla's ability to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated qualifying prior dismissals generally may not proceed without those fees unless he was in imminent danger of serious physical injury when he filed. The court found that the allegations did not show such imminent danger. It therefore ruled that Bonilla could not proceed without paying the filing fees.
The court further stated that, even if an application to proceed without those fees were granted, the lawsuits would be barred under the legal doctrines or authorities identified as Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not separately analyze each doctrine in detail.
Disposition
The court dismissed the cases with prejudice. It also 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 court additionally ruled that these were not cases in which the presiding judge's impartiality could reasonably be questioned because of the repetitive and allegedly frivolous filings. Judge Phyllis J. Hamilton signed the order on January 6, 2025.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.