Bonilla v. White
- Phyllis Hamilton
- 4:20-cv-03402
- U.S. District Court · Northern District of California
- 2
In Bonilla v. White, Judge Hamilton dismissed the cases with prejudice after finding no imminent danger and several legal barriers to the lawsuits.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice; the order also ended the pending motions and closed those cases.
What happened
In Bonilla v. White, Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights lawsuits without a lawyer against various federal or state judges. He challenged matters involving his conviction and the handling of his earlier requests for habeas relief.
Bonilla asked to proceed without paying the filing fee. The court found that he had previously been barred from proceeding that way unless he showed an imminent danger of serious physical injury, and that his allegations did not make that showing. The court also said the lawsuits would be barred even if the fee request were granted.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, and closed the cases. She also ordered the clerk to return future documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. White · No. 4:20-cv-03402
- Phyllis Hamilton
- July 6, 2020
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints named various federal or state judges as defendants. The opinion says the complaints were two similar versions in which Bonilla changed the defendant's name. He sought relief concerning his underlying conviction and the handling of his various requests for habeas relief by state and federal courts.
Bonilla also sought permission to proceed without paying the filing fee. The opinion notes that he had appointed counsel in a pending federal habeas petition and was represented by counsel in state habeas proceedings.
Court’s analysis
The court held that Bonilla was disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless he was under an imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger.
The court further stated that, even if the fee applications were granted, the lawsuits would be barred under several legal doctrines or rules identified in the opinion: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not decide the underlying validity of Bonilla’s conviction or habeas proceedings.
The court also rejected the suggestion that the assigned judge’s impartiality could reasonably be questioned, citing the general duty of a judge to hear assigned cases absent legitimate reasons for recusal.
Disposition
Judge Phyllis J. Hamilton dismissed the cases with prejudice. 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 basis
This is a procedural order. The court disposed of the cases based on the filing-fee restriction and other threshold legal barriers rather than deciding the merits of Bonilla’s civil-rights allegations.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.