Bonilla v. Simmons
- Phyllis Hamilton
- 4:25-cv-00794
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Averill, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without fees and the suits were barred.
Steven Wayne Bonilla’s multiple § 1983 cases were dismissed with prejudice; the named federal and state officials were defendants in those cases.
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 state and federal court cases were handled.
The court ruled that Bonilla could not proceed without paying filing fees because his allegations did not show imminent danger of serious physical injury. The court also said that, even if he could proceed without those fees, the lawsuits were barred by several legal rules, including rules concerning challenges to convictions and interference with ongoing cases.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and closed the cases. The clerk was directed to return any further documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Simmons · No. 4:25-cv-00794
- Phyllis Hamilton
- Jan. 30, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints under 42 U.S.C. § 1983, the federal law that allows certain civil-rights claims against state actors. He represented himself in these cases. The complaints were nearly identical and named various federal and state judges and other officials as defendants. They sought relief related to Bonilla’s underlying conviction or to the handling of his other cases in state and federal court.
The order covers the case numbers listed in the caption, including 24-cv-9255-PJH, 24-cv-9265-PJH, 25-cv-0004-PJH, and the additional cases listed there.
Court’s analysis
The court addressed Bonilla’s ability to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from proceeding without that fee may do so only if the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show such danger, so he could not proceed without paying the filing fee.
The court further stated that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under the legal rules discussed in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion also stated that Bonilla had an extensive history of filing similar cases.
The court rejected any argument that Judge Hamilton’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the 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. It also directed the clerk to return, without filing, any further documents Bonilla submitted in those closed cases.
Judge
The order was signed by Phyllis J. Hamilton, United States District Judge, on January 30, 2025.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.