Bonilla v. The Void Judgement of Alameda County, Case No. H-12210-A
- Phyllis Hamilton
- 4:20-cv-03658
- U.S. District Court · Northern District of California
- 2
In Steven Wayne Bonilla v. Defendants, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying and the claims were barred.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice. The order also affected the named federal judges, state judges, municipalities, and state and county officials because the claims against them were terminated.
What happened
Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights lawsuits under a federal law against federal judges, state judges, municipalities, and state and county officials. He challenged his conviction and the handling of his state and federal petitions seeking release from custody.
The court ruled that Bonilla could not proceed without paying filing fees because he had already been barred under the prisoner-filing statute and had not shown that he faced imminent danger when he filed the complaints. The court also said that, even if he could proceed without paying, the lawsuits would be barred by several legal rules protecting criminal judgments and limiting challenges to pending or completed court proceedings. It dismissed the cases with prejudice, closed them, and directed the clerk to return later submissions without filing them.
Judge Phyllis J. Hamilton issued the June 11, 2020 order dismissing the multiple cases and terminating all pending motions.
The detailed version
- Bonilla v. The Void Judgement of Alameda County, Case No. H-12210-A · No. 4:20-cv-03658
- Phyllis Hamilton
- June 11, 2020
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute commonly used to sue state actors for constitutional violations. He also asked to proceed without paying filing fees. The complaints named various federal judges, state judges, municipalities, and state and county officials as defendants.
The court said that Bonilla presented very similar claims in the cases. According to the order, he sought relief concerning his underlying conviction and the handling of his self-filed petitions seeking release from custody. The order also noted that he had a pending federal petition with appointed counsel and was represented by counsel in state-court proceedings involving such a petition.
Reasoning
The court stated that Bonilla had already been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g). It further found that the complaints did not show that he faced imminent danger when he filed them. For that reason, he could not proceed without paying the filing fees.
The court additionally stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The order did not separately analyze each complaint or explain which named defendant was covered by which rule.
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 after the cases were closed. Judge Phyllis J. Hamilton signed the order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.