Bonilla v. Blum
- Phyllis Hamilton
- 4:25-cv-00901
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Averill, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and concluding legal barriers barred the lawsuits.
Steven Wayne Bonilla's multiple related lawsuits were dismissed with prejudice; the listed defendants and pending motions were affected by the closure and termination orders.
What happened
In Steven Wayne Bonilla v. Averill et al., Bonilla, a state prisoner, filed multiple complaints without a lawyer under a federal civil-rights law. He named various federal and state judges and other officials, seeking relief related to his conviction and the handling of his other cases.
The court said Bonilla could not proceed without paying filing fees because he had previously been barred from doing so unless he showed that he faced an immediate danger of serious physical injury. The court found that his complaints did not show that danger. It also said that, even if he could proceed without paying fees, other legal barriers would bar the lawsuits.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and closed the cases. The clerk was ordered to return without filing any further documents Bonilla submitted in the closed cases.
The detailed version
- Bonilla v. Blum · No. 4:25-cv-00901
- Phyllis Hamilton
- Jan. 30, 2025
Background
The order covers multiple related civil-rights cases filed by Steven Wayne Bonilla, a state prisoner proceeding without a lawyer. The complaints were brought under 42 U.S.C. § 1983 and presented nearly identical claims. Bonilla named various federal and state judges and other officials as defendants. The order says he sought relief concerning his underlying conviction or the handling of his other cases.
The order also notes that Bonilla has a pending federal petition challenging his imprisonment in the same court, where he has appointed counsel, and that he is represented by counsel in state-court proceedings concerning his imprisonment.
Court's reasoning
The court addressed Bonilla's ability to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated the relevant prior dismissals generally may not proceed without paying the filing fee unless the complaint shows that the prisoner faced an imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla's allegations did not show such a danger. It therefore held that he could not proceed without paying the filing fee.
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred by the legal rules identified in the order, including rules concerning challenges that would undermine a conviction, interference with ongoing state proceedings, and attempts to obtain relief unavailable through these lawsuits. The court also rejected any claim that the judge's impartiality could reasonably be questioned merely because Bonilla had filed repetitive and frivolous cases and had named the judge as a defendant in four of them without making specific allegations.
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 those closed cases.
Classification
This is a procedural order because the court disposed of the cases based on filing-fee restrictions and other threshold legal barriers rather than deciding whether Bonilla's underlying civil-rights claims were legally valid.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.