Bonilla v. Thomas
- Phyllis Hamilton
- 4:20-cv-04307
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Thomas, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without prepaying fees and his lawsuits were barred.
Steven Wayne Bonilla's multiple § 1983 civil-rights cases were dismissed with prejudice, affecting the claims he brought against various federal and state judges, municipalities, and other court officials.
What happened
Bonilla v. Thomas involved multiple lawsuits by Steven Wayne Bonilla, a state prisoner proceeding without a lawyer. He brought civil-rights claims under a federal law allowing lawsuits over rights violations, naming federal and state judges, municipalities, and other court officials. His claims concerned his conviction and how courts handled his other cases and petitions.
The court ruled that Bonilla could not proceed without prepaying filing fees because his allegations did not show that he faced an immediate danger of serious physical injury when he filed the complaints. The court also said that, even if he were allowed to proceed without prepaying fees, the lawsuits would be barred by several legal rules identified in the order.
The court dismissed the cases with prejudice, meaning the order used that stated form of dismissal. Judge Hamilton also said her impartiality could not reasonably be questioned. The clerk was directed to end all pending motions, close the cases, and return future documents submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Thomas · No. 4:20-cv-04307
- Phyllis Hamilton
- July 6, 2020
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The opinion lists 16 related case numbers. Bonilla was a condemned prisoner with a pending federal petition challenging his custody, for which he had appointed counsel, and he was also represented by counsel in state-court proceedings. In these civil-rights cases, he named various federal judges, state judges, municipalities, and other court officials as defendants.
The complaints presented similar claims. They sought relief concerning Bonilla's underlying conviction and the handling of his other petitions and cases in state and federal courts.
Filing-fee status and dismissal
The court stated that Bonilla had been disqualified from proceeding in forma pauperis—that is, without prepaying the filing fee—under 28 U.S.C. § 1915(g), unless he showed that he was in imminent danger of serious physical injury when he filed each complaint. The court found that the allegations did not show such danger. As a result, Bonilla could not proceed without prepaying the filing fees.
The court further stated that, even if an application to proceed without prepaying fees were granted, the lawsuits would be barred under the legal rules discussed in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion does not separately analyze each rule's application to each complaint.
Ruling and case administration
The court dismissed the cases with prejudice. It also stated that the judge's impartiality could not reasonably be questioned and cited United States v. Holland regarding a judge's duty to decide assigned cases absent legitimate grounds for recusal. The clerk was ordered to terminate all pending motions and close the cases. The clerk was also ordered to return, without filing, any additional documents Bonilla submitted in the closed cases.
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.