Bonilla v. Lloyd
- Phyllis Hamilton
- 4:20-cv-03352
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Lloyd, Judge Hamilton ruled Bonilla could not proceed without paying filing fees and dismissed his multiple civil-rights cases with prejudice.
Steven Wayne Bonilla, whose multiple lawsuits were dismissed with prejudice and who was not allowed to proceed without paying filing fees; the cases were closed and later submissions were to be returned without filing.
What happened
Bonilla v. Lloyd involved multiple civil-rights lawsuits filed by Steven Wayne Bonilla, a state prisoner representing himself. He sued various federal or state judges over his conviction and the handling of his state and federal petitions challenging his imprisonment.
Bonilla asked to proceed without paying filing fees. The court ruled that he did not show an immediate danger of serious physical injury when he filed, so he could not proceed that way. The court also said that, even if he had been allowed to proceed without paying fees, the lawsuits would be barred under several legal rules and earlier decisions.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, and closed the cases. The clerk was instructed to return any additional documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Lloyd · No. 4:20-cv-03352
- Phyllis Hamilton
- July 6, 2020
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints representing himself under 42 U.S.C. § 1983, a federal civil-rights statute. He also sought permission to proceed in forma pauperis (IFP), meaning without paying the filing fees at the outset. The opinion addresses multiple cases, including case numbers 20-cv-03347-PJH, 20-cv-03348-PJH, 20-cv-03350-PJH, 20-cv-03352-PJH, 20-cv-03353-PJH, 20-cv-03355-PJH, 20-cv-03398-PJH, 20-cv-03402-PJH, 20-cv-03403-PJH, 20-cv-04231-PJH, 20-cv-04233-PJH, and 20-cv-04234-PJH.
The complaints named various federal or state judges as defendants. According to the court, the complaints were variations of two similar complaints in which Bonilla changed the defendant's name. The requested relief concerned his underlying conviction and the handling of his pro se habeas petitions by state and federal courts. The court also noted that Bonilla had a pending federal habeas petition in the same court with appointed counsel and was represented by counsel in state habeas proceedings.
IFP ruling
The court stated that Bonilla had previously been disqualified from proceeding IFP under 28 U.S.C. § 1915(g), unless he showed that he was in imminent danger of serious physical injury when he filed the complaint. The court found that the allegations did not show such imminent danger. It therefore ruled that Bonilla could not proceed IFP.
Additional grounds for dismissal
The court further stated that, even if an IFP application 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 did not reach the underlying merits of Bonilla's challenges to his conviction or to the handling of his petitions.
Recusal and disposition
The court also stated that these cases were not matters in which the undersigned judge's impartiality could reasonably be questioned. It cited the principle that, absent legitimate reasons for recusal, a judge has a duty to hear assigned cases.
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases.
Result
Judge Phyllis J. Hamilton dismissed the multiple cases with prejudice and ruled that Bonilla could not proceed IFP. The order was based on the IFP restriction and other procedural legal bars, rather than a decision on the merits of his underlying claims.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.