Bonilla
- Phyllis Hamilton
- 4:20-cv-02986
- U.S. District Court · Northern District of California
- 2
In Bonilla, Judge Hamilton dismissed the prisoner’s multiple civil-rights cases with prejudice after finding no imminent danger and identifying additional legal bars.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The order also affected the various federal and state judges, municipalities, and other state and county officials named as defendants because the cases against them were closed.
What happened
In Bonilla, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights lawsuits against various federal and state judges, municipalities, and other state and county officials. He also asked to proceed without paying the filing fees.
The court found that Bonilla was already barred from proceeding without paying under a federal prisoner-filing rule and that his complaints did not show he faced imminent danger when he filed them. The court also said the lawsuits would be barred even if his fee requests were granted because of several legal doctrines and prior decisions.
Judge Hamilton dismissed the cases with prejudice, ended all pending motions, and closed the cases. The clerk was directed to return any further documents Bonilla submitted after the cases were closed without filing them.
The detailed version
- Bonilla · No. 4:20-cv-02986
- Phyllis Hamilton
- June 11, 2020
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints under 42 U.S.C. § 1983, the federal civil-rights statute used for claims against state actors. He represented himself in these cases and asked to proceed without paying the filing fees. The complaints named various federal judges, state judges, municipalities, and other state and county officials. According to the order, the complaints presented similar claims seeking relief related to Bonilla’s underlying conviction or the way his self-represented habeas petitions had been handled by state and federal courts.
The order also noted that Bonilla was a condemned prisoner with a pending federal habeas petition in the same court, where he had appointed counsel, and that he was represented by counsel in state habeas proceedings.
Court’s Analysis
The court stated that Bonilla had already been disqualified from proceeding without paying under 28 U.S.C. § 1915(g). It further found that the allegations did not show that he was in imminent danger when he filed the complaints. For that reason, he could not proceed without paying the filing fees.
The court added that, even if an application to proceed without paying were granted, the lawsuits would be barred under the legal rules and decisions identified in the order: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order did not resolve the underlying civil-rights claims on their merits.
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.