Bonilla v. Blum
- Phyllis Hamilton
- 4:25-cv-00496
- U.S. District Court · Northern District of California
- 3
Bonilla v. Averill: Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla was barred from proceeding without fees and the suits faced procedural bars.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The defendants were various federal and state judges and other officials identified in the complaints.
What happened
Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights cases against various federal and state judges and other officials. He sought relief concerning his conviction and how other court cases were handled.
The court said Bonilla could not proceed without paying the filing fees because he had previously been disqualified from fee-free filing and had not shown an immediate danger of serious physical injury. The court also said that, even if he could proceed without fees, the lawsuits would be barred by several legal rules and prior decisions.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, closed the cases, and ordered the clerk to return future submissions in those cases without filing them.
The detailed version
- Bonilla v. Blum · No. 4:25-cv-00496
- Phyllis Hamilton
- Jan. 30, 2025
Background
Steven Wayne Bonilla filed multiple complaints under 42 U.S.C. § 1983, the federal civil-rights statute used for claims against government officials. The order identifies Bonilla as a state prisoner proceeding without a lawyer. The complaints were nearly identical and named various federal and state judges and other officials as defendants. They sought relief concerning Bonilla’s underlying conviction and the handling of his other state and federal cases.
The order states that Bonilla had a pending federal habeas petition in the same court with appointed counsel and was also represented by counsel in state habeas proceedings. The order does not decide those other proceedings.
Court’s reasoning
The court addressed Bonilla’s ability to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), a prisoner disqualified from fee-free filing may proceed without paying only if the complaint shows that the prisoner faced an imminent danger of serious physical injury when the complaint was filed. The court found that these complaints did not show such danger. It therefore held that Bonilla could not proceed without paying the filing fees.
The court added that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the legal rules and decisions identified in the order: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The court also noted Bonilla’s extensive history of filing similar cases.
The court separately rejected any suggestion that the assigned judge’s impartiality could reasonably be questioned merely because of the repetitive and frivolous nature of the filings. The order states that Bonilla named the judge as a defendant in four of the cases but made no specific allegations against the judge.
Disposition
The court dismissed the cases with prejudice. It 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.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.