Bonilla v. Maier
- Phyllis Hamilton
- 4:25-cv-00792
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Averill, Judge Hamilton dismissed the prisoner’s multiple civil-rights cases with prejudice, finding no imminent danger and citing additional legal barriers.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. His pending motions were terminated, the cases were closed, and further documents submitted in those closed cases were to be returned without filing.
What happened
In Bonilla v. Averill, Steven Wayne Bonilla, a condemned state prisoner proceeding without a lawyer, filed multiple nearly identical civil-rights lawsuits under a federal civil-rights statute. He sued various federal and state judges and other officials, seeking relief related to his conviction and the handling of his other cases.
The court found that Bonilla could not proceed without paying the filing fees because he had been disqualified from that status and his complaints did not show imminent danger of serious physical injury when filed. The court also said that, even if that status had been granted, the lawsuits would be barred under several legal doctrines and precedents it cited.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and closed the cases. The clerk was directed to return without filing any further documents Bonilla submitted in those closed cases.
The detailed version
- Bonilla v. Maier · No. 4:25-cv-00792
- Phyllis Hamilton
- Jan. 30, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a federal statute that permits certain civil-rights lawsuits. 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 court cases.
The opinion also noted that Bonilla had a pending federal petition challenging his custody with appointed counsel and was represented by counsel in state-court proceedings. Those related proceedings were cited in the opinion but were not the matters resolved by this order.
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 was under imminent danger of serious physical injury when he filed the complaint. The court found that the allegations did not show imminent danger at the time of filing. Accordingly, Bonilla could not proceed without paying the filing fees.
Other Grounds Cited
The court further stated that, even if an application to proceed without paying filing fees were granted, the lawsuits would be barred under Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion did not provide a separate claim-by-claim analysis of those doctrines.
The court also rejected the possibility that the judge’s impartiality could reasonably be questioned because of Bonilla’s repetitive and frivolous filings. The opinion noted that Bonilla named Judge Hamilton as a defendant in four of the cases but made no specific allegations against her in those cases.
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.