Bonilla v. Lee
- Phyllis Hamilton
- 4:25-cv-01061
- U.S. District Court · Northern District of California
- 3
Steven Wayne Bonilla v. Linda Clark et al.: Judge Hamilton dismissed 16 civil-rights cases with prejudice because Bonilla could not proceed without paying and the suits were barred.
Steven Wayne Bonilla’s 16 nearly identical civil-rights cases against the defendants named in the individual case captions were dismissed with prejudice; pending motions were terminated and the cases were closed.
What happened
In Steven Wayne Bonilla v. Linda Clark et al., Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights lawsuits without a lawyer. He sought to proceed without paying the filing fees, but the court said his allegations did not show an immediate risk of serious physical injury when he filed the cases.
The court also said that, even if Bonilla could proceed without paying, the lawsuits were barred by several legal doctrines, including rules concerning challenges to convictions, ongoing state proceedings, and federal court authority. The court dismissed all the cases with prejudice and ordered the clerk to close them and return future submissions without filing them.
Judge Phyllis J. Hamilton ruled that the judge’s impartiality could not reasonably be questioned merely because Bonilla had filed repetitive and allegedly frivolous cases. The clerk was directed to terminate all pending motions and close the cases.
The detailed version
- Bonilla v. Lee · No. 4:25-cv-01061
- Phyllis Hamilton
- Feb. 28, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The opinion states that the complaints presented nearly identical claims, but the provided text does not include the full description of those claims. Bonilla also had a pending federal petition challenging his imprisonment in this court with appointed counsel and was represented by counsel in state-court proceedings challenging his imprisonment.
Filing-fee determination
Bonilla had been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless he showed that he faced an imminent danger of serious physical injury when he filed the complaint. The court found that the allegations did not show such danger. It therefore held that Bonilla could not proceed without paying the filing fee in these cases.
Other legal barriers
The court further held that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under one or more of the following doctrines or authorities: Heck v. Humphrey, which can bar civil-rights claims that would undermine a conviction; Younger v. Harris, concerning federal interference with certain ongoing state proceedings; Demos v. U.S. District Court; and Mullis v. U.S. Bankruptcy Court. The opinion does not assign a separate disposition to each individual claim or identify which specific doctrine applies to which case.
Recusal issue
The court rejected the suggestion that the judge’s impartiality could reasonably be questioned because of Bonilla’s repetitive and allegedly frivolous filings. The opinion states that Bonilla named the judge as a defendant in two of the cases, but the provided text does not include the rest of the explanation in that footnote.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions, close the cases, and return without filing any further documents Bonilla submitted in the closed cases. Judge Phyllis J. Hamilton also noted Bonilla’s extensive history of filing similar cases, including the numbers of cases described in the opinion’s footnote.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.