Bonilla v. Maier
- Phyllis Hamilton
- 4:25-cv-00498
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Averill et al., Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla showed no imminent danger and the suits faced legal bars.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The order also terminated pending motions, closed the cases, and directed the clerk to return future submissions without filing them.
What happened
Bonilla v. Averill et al. involved multiple nearly identical civil-rights lawsuits filed without a lawyer by Steven Wayne Bonilla, a state prisoner facing a death sentence. He sued various federal and state judges and other officials over his conviction and the handling of his other cases.
The court said Bonilla was barred from proceeding without paying filing fees unless he showed that he faced an immediate danger of serious physical injury when he filed. The court found that his complaints did not make that showing. It also said that, even if he had been allowed to proceed without paying fees, the lawsuits would still be barred by other legal rules.
The court dismissed the cases with prejudice, terminated all pending motions, and ordered the clerk to close the cases and return future documents without filing them. Judge Phyllis J. Hamilton also stated that the repetitive filings did not provide a reasonable basis to question her impartiality.
The detailed version
- Bonilla v. Maier · No. 4:25-cv-00498
- Phyllis Hamilton
- Jan. 30, 2025
Background
Steven Wayne Bonilla, a state prisoner under a death sentence, filed multiple nearly identical complaints without a lawyer under 42 U.S.C. § 1983, the federal law that allows certain civil-rights claims against state officials. The complaints named various federal and state judges and other officials. They sought relief concerning Bonilla’s underlying conviction or the way his other federal and state cases had been handled.
The opinion states that Bonilla had a pending federal petition challenging his imprisonment in the same court, with appointed counsel, and was represented by counsel in state proceedings. The opinion also notes that Bonilla had an extensive 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 been disqualified from that status may proceed without paying only if the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court found that these complaints did not show such danger, so Bonilla could not proceed without paying filing 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 rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not provide a separate detailed analysis of how each rule applied to each individual complaint.
The court also stated that the repetitive and allegedly frivolous nature of the filings did not create a reasonable basis to question the assigned judge’s impartiality. It noted 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. It ordered the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in those closed cases. The order was signed by Judge Phyllis J. Hamilton on January 30, 2025.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.