Bonilla v. Reardon
- Phyllis Hamilton
- 4:20-cv-03353
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Reardon, Judge Hamilton barred Steven Wayne Bonilla from proceeding without fees, dismissed the cases with prejudice, and ordered them closed.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice; the order also prevented him from proceeding without filing fees and directed the clerk to close the cases.
What happened
In Bonilla v. Reardon, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights lawsuits against various federal or state judges. He challenged matters related to his conviction and the handling of his state and federal petitions seeking release.
The court ruled that Bonilla could not proceed without paying filing fees because he had previously been barred from fee-free filing under federal law and had not shown an immediate danger of serious physical injury when he filed. The court also said that, even if he could proceed without fees, the lawsuits would be barred by several legal doctrines. It dismissed the cases with prejudice and directed the clerk to close them and return future filings in those cases without filing them.
Judge Phyllis J. Hamilton also rejected the suggestion that her impartiality could reasonably be questioned. She ordered the clerk to terminate all pending motions and close the cases.
The detailed version
- Bonilla v. Reardon · No. 4:20-cv-03353
- Phyllis Hamilton
- July 6, 2020
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints under 42 U.S.C. § 1983, the federal civil-rights statute that allows claims against persons acting under state law. He represented himself in these cases and asked to proceed without paying filing fees. The complaints named various federal or state judges as defendants and sought relief concerning Bonilla’s underlying conviction and the handling of his state and federal petitions seeking release.
The order addresses the following 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 order also notes that Bonilla had appointed counsel in a pending federal petition and counsel in state-court proceedings.
Fee-free filing restriction
The court stated that Bonilla had previously been disqualified from proceeding without filing fees under 28 U.S.C. § 1915(g), unless he was in imminent danger of serious physical injury when he filed. The court found that the allegations did not show such danger at the relevant time. Therefore, Bonilla could not proceed without paying the required fees.
Alternative grounds for dismissal
The court further stated that, even if Bonilla’s request to proceed without fees were granted, the lawsuits would be barred under the legal rules identified in the order: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The court did not provide a separate claim-by-claim explanation of which rule applied to which lawsuit.
Disposition
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.
The order also stated that this was not a situation in which the judge’s impartiality could reasonably be questioned. Judge Phyllis J. Hamilton signed the order on July 6, 2020.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.