Bonilla v. Mayfield
- Phyllis Hamilton
- 4:25-cv-00787
- U.S. District Court · Northern District of California
- 3
In Steven Wayne Bonilla v. Averill, 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 self-represented civil-rights cases were dismissed with prejudice; the defendants were federal and state judges and other officials named in those cases.
What happened
In Steven Wayne Bonilla v. Averill et al., Steven Wayne Bonilla, a condemned state prisoner representing himself, filed many nearly identical civil-rights lawsuits against federal and state judges and other officials. The lawsuits challenged his conviction or how other state and federal cases had been handled.
The court ruled that Bonilla could not proceed without paying the filing fees because he had been barred from proceeding without fees unless he showed that he faced imminent danger of serious physical injury. The court found that his complaints did not show such danger. It also stated that, even if he could proceed without fees, the lawsuits would be barred by several legal rules and dismissed the cases with prejudice.
Judge Phyllis J. Hamilton also stated that the repetitive and frivolous filings did not reasonably call her impartiality into question. The clerk was ordered to terminate pending motions, close the cases, and return future submissions in those closed cases without filing them.
The detailed version
- Bonilla v. Mayfield · No. 4:25-cv-00787
- Phyllis Hamilton
- Jan. 30, 2025
Background
Steven Wayne Bonilla, a state prisoner sentenced to death, filed multiple complaints under 42 U.S.C. § 1983 while representing himself. The complaints were nearly identical. They named various federal and state judges and other officials as defendants and sought relief concerning Bonilla's underlying conviction or the handling of his other state and federal cases.
The opinion notes that Bonilla had a pending federal petition concerning his conviction in the same court, where he had appointed counsel, and that he was also represented by counsel in state proceedings concerning that conviction.
Proceeding Without Paying Filing Fees
The court stated that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying filing fees unless he showed that he was under imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show imminent danger at the time of filing.
Disposition
The court further stated that, even if Bonilla's applications to proceed without paying fees were granted, the lawsuits would be barred under the rules or doctrines identified in the opinion: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The court therefore dismissed the cases with prejudice.
The court also stated that the repetitive and frivolous nature of the filings did not provide a reasonable basis to question the undersigned judge's impartiality. The clerk was ordered to terminate all pending motions and close the cases. The clerk was also ordered to return, without filing, any additional documents Bonilla submitted in the closed cases.
Result
The multiple cases were dismissed with prejudice, pending motions were terminated, and the cases were closed. The opinion does not separately identify a disposition for each individual pending motion.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.