Bonilla v. Blum
- Phyllis Hamilton
- 4:25-cv-00496
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Averill, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and identifying legal barriers.
Steven Wayne Bonilla and the defendants named in his multiple civil-rights cases; the cases were dismissed with prejudice and closed.
What happened
In Steven Wayne Bonilla v. Averill et al., a state prisoner filed multiple nearly identical civil-rights cases against various federal and state judges and other officials. He sought relief concerning his conviction and the handling of his other court cases.
The court ruled that Bonilla could not proceed without paying the filing fees because his complaints did not show that he faced an imminent danger of serious physical injury when he filed them. The court also said that, even if he had been allowed to proceed without paying, the lawsuits would be barred by several legal rules.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and ordered the clerk to close the cases and return any further documents Bonilla submitted in them without filing them.
The detailed version
- Bonilla v. Blum · No. 4:25-cv-00496
- Phyllis Hamilton
- Jan. 30, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints presented nearly identical claims against various federal and state judges and other officials. They sought relief concerning Bonilla’s underlying conviction or the way his other state and federal cases had been handled.
The order also notes that Bonilla has a pending federal petition challenging his conviction in the same court with appointed counsel and is represented by counsel in state-court proceedings.
Court’s analysis
The court stated that Bonilla had been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless he showed that he was in imminent danger of serious physical injury when he filed each complaint. The court found that the allegations did not show such danger. As a result, Bonilla could not proceed without paying the filing fee.
The court further stated that, even if an application to proceed without paying the filing fee had been granted, the lawsuits would be barred under several legal doctrines and precedents, including rules concerning challenges to criminal convictions, interference with ongoing proceedings, and challenges to the handling of federal cases. The order did not decide the underlying claims in Bonilla’s favor or in the defendants’ favor.
The court also rejected any suggestion that the judge’s impartiality could reasonably be questioned because of Bonilla’s repetitive filings. The order states that Bonilla named the judge as a defendant in four of the cases but made no specific allegations against her.
Disposition
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 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.