Bonilla v. Roach
- Phyllis Hamilton
- 4:25-cv-01187
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Clark, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and applicable legal bars.
Steven Wayne Bonilla and the defendants in the 16 listed cases were affected. The cases were dismissed with prejudice, pending motions were terminated, the cases were closed, and later documents submitted in those closed cases were to be returned without filing.
What happened
In Steven Wayne Bonilla v. Linda Clark et al., the court addressed multiple nearly identical civil-rights complaints filed by Bonilla, a state prisoner. Judge Hamilton was assigned to the cases.
Bonilla filed the complaints without a lawyer under a federal civil-rights law. The opinion says he is a condemned prisoner with a pending federal petition in the same court and representation in state-court proceedings. The court found that his allegations did not show imminent danger when he filed the complaints.
Judge Phyllis J. Hamilton dismissed the cases with prejudice. The court also ruled that, even if Bonilla could proceed without paying the filing fee, the lawsuits would be barred by several legal doctrines, and it directed the clerk to terminate pending motions, close the cases, and return later submissions without filing them.
The detailed version
- Bonilla v. Roach · No. 4:25-cv-01187
- Phyllis Hamilton
- Feb. 28, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The opinion says the complaints presented nearly identical claims. The excerpt does not fully describe those claims; part of the discussion is incomplete.
The opinion also says that Bonilla is a condemned prisoner with a pending federal petition in this court and is represented by counsel in state-court proceedings. The court noted that Bonilla had an extensive history of filing similar cases.
Filing-Fee Issue
To the extent Bonilla sought permission to proceed without paying the filing fee, the court held that he was disqualified under 28 U.S.C. § 1915(g). That statute permits a disqualified prisoner to proceed without the fee only when the complaint shows that the prisoner was in imminent danger of serious physical injury when the complaint was filed. The court found that the allegations did not show such danger.
Other Bars and Ruling
The court further held that, even if an application to proceed without paying the fee 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 does not explain which specific bar applies to which case or claim.
The court dismissed the cases with prejudice. It also rejected the suggestion that the judge's impartiality could reasonably be questioned because of the repetitive and allegedly frivolous filings. The clerk was directed to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases.
Classification
This is a procedural order because the court disposed of the cases based on filing-fee eligibility and threshold legal bars rather than deciding the underlying civil-rights claims on their merits.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.