Bonilla v. Roach
- Phyllis Hamilton
- 4:25-cv-01233
- U.S. District Court · Northern District of California
- 3
Bonilla v. Clark: Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without prepayment and the lawsuits were barred.
Steven Wayne Bonilla’s 16 related civil-rights cases were dismissed with prejudice; the clerk was directed to close them and return later filings without filing them.
What happened
In Bonilla v. Clark et al., Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits under a federal statute. The opinion lists 16 related case numbers and says Bonilla also has pending federal and state court challenges involving his conviction.
The court found that Bonilla was barred from proceeding without prepaying the filing fee unless he showed an immediate serious physical danger, and his complaints did not make that showing. The court also stated that the lawsuits would be barred even if his applications to proceed without prepayment were granted.
Judge Phyllis Hamilton dismissed the cases with prejudice, terminated all pending motions, closed the cases, and directed the clerk to return future filings in those cases without filing them.
The detailed version
- Bonilla v. Roach · No. 4:25-cv-01233
- Phyllis Hamilton
- Feb. 28, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, the federal law commonly used to bring civil-rights claims against state actors. The court said the complaints presented nearly identical claims. It also noted that Bonilla is a condemned prisoner with a pending federal petition challenging his custody or conviction, represented by appointed counsel, and that he is represented by counsel in state court proceedings.
Proceeding Without Prepayment
The court stated that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding without prepaying the filing fee unless he was in immediate danger of serious physical injury when he filed his complaints. The court found that the allegations did not show that he was in such danger at the relevant time. As a result, Bonilla could not proceed without prepaying the filing fee.
Other Bars and Disposition
The court further stated that, even if an application to proceed without prepayment were granted, the lawsuits would be barred under the authorities it cited: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion did not assign each cited bar to a particular complaint or explain the application of each authority in detail. 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 frivolous filings, including because Bonilla named the judge as a defendant in two cases. The clerk was directed to terminate all pending motions, close the cases, and return without filing any further documents Bonilla submitted in the closed cases.
Classification Basis
This is a procedural order. The court dismissed the cases based on the filing-fee restriction and stated procedural and other legal bars without deciding the underlying civil-rights claims on their merits.
Judge’s Additional Observations
The court stated that Bonilla had an extensive history of filing similar cases. A footnote said the judge was the fourth judge assigned to Bonilla’s cases, and that the judge had issued an order concerning 1,064 different cases filed by Bonilla. The opinion did not provide additional merits analysis of the claims in these cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.