Bonilla v. All Reviewing Courts
- Phyllis Hamilton
- 4:20-cv-04318
- U.S. District Court · Northern District of California
- 2
In Bonilla v. All Reviewing Courts, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying filing fees.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice, and he could not proceed in those cases without paying the required filing fees.
What happened
In Bonilla v. All Reviewing Courts, Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple civil-rights lawsuits against federal judges, state judges, municipalities, and other court officials. His claims concerned his conviction and how state and federal courts handled his other cases.
The court said Bonilla had previously lost the ability to proceed without paying filing fees under federal law unless he showed an imminent danger of serious physical injury. The court found that his complaints did not show such danger. It also said that, even if he could proceed without paying, the lawsuits would be barred by several legal rules and prior decisions.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, and ordered the clerk to close the cases. The clerk was also ordered to return future documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. All Reviewing Courts · No. 4:20-cv-04318
- Phyllis Hamilton
- July 6, 2020
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints named various federal judges, state judges, municipalities, and other court officials as defendants. The court said the cases presented very similar claims about Bonilla’s underlying conviction and the handling of his pro se habeas petitions and other cases.
The opinion also noted that Bonilla had a pending federal petition challenging his imprisonment in the same court, with appointed counsel, and was represented by counsel in state-court proceedings.
Filing-fee status
The court stated that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding in forma pauperis, meaning without paying the required filing fees, unless he was in imminent danger of serious physical injury when he filed his complaints. The court found that the allegations did not show imminent danger at that time. It therefore concluded that Bonilla could not proceed without paying the fees.
Other grounds for dismissal
The court added that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the legal rules and decisions cited as Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not separately analyze each cited basis.
The court also addressed whether the judge’s impartiality could reasonably be questioned and concluded that these were not cases requiring the judge’s recusal. It cited the principle that, absent legitimate reasons for recusal, a judge has a duty to decide assigned cases.
Disposition
Judge Phyllis J. Hamilton dismissed the cases with prejudice. The clerk was ordered to terminate all pending motions and close the cases. The clerk was also ordered to return, without filing, any further documents Bonilla submitted in the closed cases. Because the court disposed of the cases on filing-fee and other threshold grounds rather than deciding the underlying civil-rights claims, this is a procedural order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.